Emission Factor Documentation for AP-42 Lime Manufacturing ...

Emission Factor Documentation for AP-42Section 11.15

Lime Manufacturing

Final Report

For U. S. Environmental Protection AgencyOffice of Air Quality Planning and Standards

Emission Inventory Branch

EPA Contract 68-D2-0159Work Assignment No. I-01

MRI Project No. 4601-01

April 28, 1994

EFIG

This is actually 11.17. 11.15 is Glass Manufacturing

Emission Factor Documentation for AP-42Section 11.15

Lime Manufacturing

Final Report

For U. S. Environmental Protection AgencyOffice of Air Quality Planning and Standards

Emission Inventory BranchResearch Triangle Park, NC 27711

Attn: Mr. Ron Myers (MD-14)Emission Factor and Methodology

EPA Contract 68-D2-0159Work Assignment No. I-01

MRI Project No. 4601-01

April 28, 1994

iii

PREFACE

This report was prepared by Midwest Research Institute (MRI) for the Office of Air Quality

Planning and Standards (OAQPS), U. S. Environmental Protection Agency (EPA), under Contract

No. 68-D2-0159, Work Assignment No. I-01. Mr. Ron Myers was the requester of the work. The report

was prepared by Richard Marinshaw, Dennis Wallace, Brian Shrager, and Ed Sanderford.

Approved for:

MIDWEST RESEARCH INSTITUTE

Roy Neulicht

Program Manager

Environmental Engineering

Department

Jeff Shular

Director, Environmental Engineering

Department

April 28, 1994

iv

v

CONTENTS

Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iiiList of Figures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . viiList of Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii

1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2. INDUSTRY DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22.1 CHARACTERIZATION OF THE INDUSTRY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22.2 PROCESS DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22.3 EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72.4 CONTROL TECHNOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3. GENERAL DATA REVIEW AND ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93.1 LITERATURE SEARCH AND SCREENING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93.2 EMISSION DATA QUALITY RATING SYSTEM . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103.3 EMISSION FACTOR QUALITY RATING SYSTEM . . . . . . . . . . . . . . . . . . . . . . . . . . 11

4. AP-42 SECTION DEVELOPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 124.1 REVISION OF SECTION NARRATIVE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 124.2 POLLUTANT EMISSION FACTOR DEVELOPMENT . . . . . . . . . . . . . . . . . . . . . . . . 12

4.2.1 Review of Specific Data Sets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 244.2.2 Estimate of Theoretical CO2 Emission Factors for Lime Kilns . . . . . . . . . . . . . . . 384.2.3 Review of XATEF and SPECIATE Data Base Emission Factors . . . . . . . . . . . . . 384.2.4 Review of Test Data in AP-42 Background File . . . . . . . . . . . . . . . . . . . . . . . . . . 394.2.5 Results of Data Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

5. REVISED AP-42 SECTION 11.15 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

APPENDIX A

vi

vii

LIST OF FIGURES

Number Page

2-1. Process flow diagram for lime manufacturing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42-2 Operation of parallel flow regenerative lime kiln . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

LIST OF TABLES

Number Page

2-1. 1989 Domestic lime production by State . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34-1. Summary of emission test reports used to develop emission factors . . . . . . . . . . . . . 134-2. References not used to develop emission factors . . . . . . . . . . . . . . . . . . . . . . . . . . . 154-3. Summary of test data for lime manufacturing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 164-4. Average particle size distribution for rotary lime kilns . . . . . . . . . . . . . . . . . . . . . . . 234-5. Summary of average emission factors for lime manufacturing . . . . . . . . . . . . . . . . . 40

1

EMISSION FACTOR DOCUMENTATION FOR AP-42 SECTION 11.15Lime Manufacturing

1. INTRODUCTION

The document Compilation of Air Pollutant Emission Factors (AP-42) has been published by theU.S. Environmental Protection Agency (EPA) since 1972. Supplements to AP-42 have been routinelypublished to add new emission source categories and to update existing emission factors. AP-42 isroutinely updated by EPA to respond to new emission factor needs of EPA, State and local air pollutioncontrol programs, and industry.

An emission factor relates the quantity (weight) of pollutants emitted to a unit of activity of thesource. The uses for the emission factors reported in AP-42 include:

1. Estimates of areawide emissions;

2. Estimates of emissions for a specific facility; and

3. Evaluation of emissions relative to ambient air quality.

The purpose of this report is to provide background information from test reports and otherinformation to support revision of AP-42 Section 11.15, Lime Manufacturing.

This background report consists of five sections. Section 1 includes the introduction to thereport. Section 2 gives a description of the Lime Manufacturing industry. It includes a characterizationof the industry, an overview of the different process types, a description of emissions, and a descriptionof the technology used to control emissions resulting from lime manufacturing. Section 3 is a review ofemission data collection and laboratory analysis procedures. It describes the literature search, thescreening of emission data reports, and the quality rating system for both emission data and emissionfactors. Section 4 details revisions to the existing AP-42 section narrative and pollutant emission factordevelopment. It includes a review of specific data sets and the results of data analysis. Section 5presents AP-42 Section 11.15, Lime Manufacturing.

2

2. INDUSTRY DESCRIPTION1-5

Lime is the high-temperature product of the calcination of limestone. Although limestonedeposits are found in every State, only a small portion is pure enough for industrial lime manufacturing. To be classified as limestone, the rock must contain at least 50 percent calcium carbonate (CaCO3). When the rock contains 30 to 45 percent magnesium carbonate, it is referred to as dolomite, or dolomiticlimestone. Lime can also be produced from aragonite, chalk, coral, marble, and sea shells.

The Standard Industry Classification (SIC) code for lime manufacturing is 3274. The first sixdigits of lime manufacturing Source Classification Codes (SCC) are 3-05-016.

2.1 CHARACTERIZATION OF THE INDUSTRY1,2,5

During 1989, approximately 15.6 million megagrams (Mg) (17.1 million tons) of lime wereproduced at 116 U.S. plants. Table 2-1

3

TABLE 2-1. 1989 DOMESTIC LIME PRODUCTION BY STATE5

State No. of plants

Production Value,thousands, $Mg tons

AlabamaArizonaArkansas, Louisiana, OklahomaCaliforniaColorado, Nevada, Wyoming

533

119

1,344W

259358324

1,481W

286395357

70,361W

15,54824,50324,136

Hawaii, Oregon, WashingtonIdahoIllinois, Indiana, MissouriIowa, Nebraska, South DakotaKentucky, Tennessee, West Virginia

43845

357W

3,315W

1,473

393W

3,654W

1,624

26,348W

168,979W

89,859

MassachusettsMichiganMinnesota and MontanaNorth DakotaOhio

28739

W563

W97

1,713

W621

W108

1,888

W32,479

W5,439

94,157

PennsylvaniaPuerto RicoTexasUtahVirginiaWisconsin

1018454

1,50624

1,183338745396

1,66026

1,304373821437

92,1393,800

60,82917,97438,353

181,129

Other a 1,588 1,750 72,880

TOTAL 116 15,584 17,178 855,913

aIncluded with data for individual States. W = withheld to avoid disclosing company proprietary data; included in other.

4

summarizes domestic lime production by State in 1989.

There are two kinds of lime: high-calcium lime (CaO) and dolomitic lime (CaO@MgO). Morethan 90 percent of limestone mines are from open-pit operations; the remainder are underground. Themajor uses of lime are metallurgical (aluminum, steel, copper, silver, and gold industries), environmental(flue gas desulfurization, water softening, pH control, sewage-sludge destabilization, and hazardouswaste treatment), and construction (soil stabilization, asphalt additive, and masonry lime). In 1989, about14 percent of all lime produced was converted to hydrated (slaked) lime, and 3.6 percent was convertedto dead-burned dolomite. Dead-burned dolomitic lime, or refractory lime, is a sintered form of dolomiticlime that is calcined at high temperatures with the addition of iron oxide. Dead-burned dolomitic lime isused primarily as a refractory for lining steel furnaces.

2.2 PROCESS DESCRIPTION1-4,6

Lime is manufactured in various kinds of kilns by one of the following reactions:

CaCO3 + heat 6 CO2 + CaO (high-calcium lime)

CaCO3@MgCO3 + heat 6 2 CO2 + CaO@MgO (dolomitic lime)

The basic processes in the production of lime are (1) quarrying raw limestone; (2) preparing thelimestone for the kilns by crushing and sizing; (3) calcining the limestone; (4) processing the lime furtherby hydration; and (5) miscellaneous transfer, storage, and handling operations. A generalized materialflow diagram for a lime manufacturing plant is given in Figure 2-1

5

Figure 2-1. Process flow diagram for lime manufacturing.4

6

. Note that some operations shown may not be performed in all plants.

The heart of a lime plant is the kiln. The prevalent type of kiln is the rotary kiln, accounting forabout 90 percent of all lime production in the United States. This kiln is a long, cylindrical, slightlyinclined, refractory-lined furnace through which the limestone and hot combustion gases passcountercurrently. Coal, oil, and natural gas may all be fired in rotary kilns. Product coolers andlimestone preheaters of various types are commonly used to recover heat from the hot lime product andhot exhaust gases, respectively.

7

8

The next most common type of kiln in the United States is the vertical, or shaft, kiln. This kilncan be described as an upright heavy steel cylinder lined with refractory material. The limestone ischarged at the top and is calcined as it descends slowly to discharge at the bottom of the kiln. A primaryadvantage of vertical kilns over rotary kilns is higher average fuel efficiency. The primary disadvantagesof vertical kilns are their relatively low production rates and the fact that coal cannot be used withoutdegrading the quality of the lime produced. There have been few recent vertical kiln installations in theUnited States because of high product quality requirements.

Other, much less common, kiln types include rotary hearth and fluidized bed kilns. Both kilntypes can achieve high production rates, and neither can operate with coal. The "calcimatic" kiln, orrotary hearth kiln, is a circular kiln with a slowly revolving doughnut-shaped hearth. In fluidized bedkilns, finely divided limestone is brought into contact with hot combustion air in a turbulent zone, usuallyabove a perforated grate. Because of the amount of lime carryover into the exhaust gases, dust collectionequipment must be installed on fluidized bed kilns for process economy.

Another alternative process that is beginning to emerge in the United States is the parallel flowregenerative (PR) lime kiln. This process combines two advantages. First, optimum heating conditionsfor lime calcining are achieved by concurrent flow of the charge material and combustion gases. Second,the multiple-chamber regenerative process uses the charge material as the heat transfer medium topreheat the combustion air. The basic PR system has two shafts, but three-shaft systems are used withsmall size grains to address the increased flow resistance associated with smaller feed sizes.

In the two-shaft system, the shafts alternate functions, with one shaft serving as the heating shaftand the other as the flue gas shaft. Figure 2-2

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Figure 2-2. Operation of parallel flow regenerative lime kiln.6

10

illustrates the operation of the two-shaft PR kiln. Each shaft includes a heating zone, acombustion/burning zone, and a cooling zone. Limestone is charged alternatively to the two shafts andflows downward by gravity flow. The two shafts are connected in the middle to allow gas flow betweenthem. In the heating shaft, combustion air flows downward through the heated charge material. Afterbeing preheated by the charge material, the combustion air combines with the fuel (natural gas or oil),and the air/fuel mixture is fired downward into the combustion zone. The hot combustion gases passfrom the combustion zone in the heating shaft to the combustion zone in the flue gas shaft. The heatedexhaust gases flow upward through the flue gas shaft combustion zone and into the preheating zonewhere they heat the charge material. The function of the two shafts reverses on a 12-minute cycle. Thebottom of both shafts is a cooling zone. Cooling air flows upward through the shaft countercurrently tothe flow of the calcined product. This air mixes with the combustion gases in the crossover areaproviding additional combustion air. The product flows by gravity from the bottom of both shafts.

About 15 percent of all lime produced is converted to hydrated (slaked) lime. There are twokinds of hydrators, atmospheric and pressure. Atmospheric hydrators, the more prevalent type, are usedin continuous mode to produce high-calcium and dolomitic hydrates. Pressure hydrators, on the otherhand, produce only a completely hydrated dolomitic lime and operate only in batch mode. Generally,water sprays or wet scrubbers perform the hydrating process and prevent product loss. Followinghydration, the product may be milled and then conveyed to air separators for further drying and removalof coarse fractions.

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2.3 EMISSIONS1-4,7

Potential air pollutant emission points in lime manufacturing plants are indicated by SCC inFigure 2-1. Except for gaseous pollutants emitted from kilns, particulate matter (PM) is the dominantpollutant. Emissions of filterable PM from rotary lime kilns constructed or modified after May 3, 1977are regulated to 0.30 kilograms per megagram (kg/Mg) (0.60 pounds per ton [lb/ton]) of stone feed under40 CFR Part 60, subpart HH.

The largest ducted source of PM is the kiln. Of the various kiln types, fluidized beds have thehighest levels of uncontrolled PM emissions because of the very small feed rate combined with high airflow through these kilns. Fluidized bed kilns are well controlled for maximum product recovery. Therotary kiln is second worst in uncontrolled PM emissions because of the small feed rate, the relativelyhigh air velocities, and the dust entrainment caused by the rotating chamber. The calcimatic (rotaryhearth) kiln ranks third in dust production, primarily because of the larger feed size and the fact that,during calcination, the limestone remains stationary relative to the hearth. The vertical kiln has thelowest uncontrolled dust emissions due to the large lump feed, the relatively low air velocities, and theslow movement of material through the kiln. In coal-fired kilns, the properties of the limestone feed andthe ash content of the coal can significantly affect PM emission rates.

Carbon monoxide (CO), carbon dioxide (CO2), sulfur dioxide (SO2), and nitrous oxides (NOx)are all produced in kilns. Sulfur dioxide emissions are influenced by the sulfur content of the fuel, thesulfur content of the stone feed, the mineralogical forms (pyritic or gypsum) of the stone feed, the qualityof lime being manufactured, and the type of kiln. The dominant source of sulfur emissions is the kilnfuel, and the vast majority of the fuel sulfur is not emitted because of reactions with calcium oxides in thekiln. Sulfur dioxide emissions may be further reduced if the pollution equipment uses a wet process or ifit brings CaO and SO2 into intimate contact.

Product coolers are emission sources only when some of their exhaust gases are not recycledthrough the kiln for use as combustion air. The trend is toward recycling cooler exhaust as combustionair to maximize fuel efficiencies. This reduces emissions from product coolers.

Hydrator emissions are low, because water sprays or wet scrubbers are usually installed toprevent product loss in the exhaust gases. Emissions from pressure hydrators may be higher than fromthe more common atmospheric hydrators because the exhaust gases are released intermittently, makingcontrol more difficult.

Other particulate sources in lime plants include primary and secondary crushers, mills, screens,mechanical and pneumatic transfer operations, storage piles, and roads. If quarrying is a part of the limeplant operation, particulate may also result from drilling and blasting. Emission factors for some of theseoperations are presented in Sections 11.19 and 13.2 of AP-42.

2.4 CONTROL TECHNOLOGY4

Some sort of particulate control is generally applied to most kilns. Rudimentary fallout chambersand cyclone separators are commonly used to control larger particles. Fabric and gravel bed filters, wet(commonly, venturi) scrubbers, and electrostatic precipitators (ESP's) are used for secondary control.

For particulate control, cyclones, fabric filters, and wet scrubbers are also used on coolers andducted emission sources such as crushers and loaders.

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REFERENCES FOR SECTION 2

1. Screening Study For Emissions Characterization From Lime Manufacture, EPA ContractNo. 68-02-0299. Vulcan-Cincinnati, Inc., Cincinnati, OH. August 1974.

2. Standards Support And Environmental Impact Statement, Volume I: Proposed Standards OfPerformance For Lime Manufacturing Plants, EPA-450/2-77-007a, U. S. Environmental ProtectionAgency, Research Triangle Park, NC. April 1977.

3. National Lime Association, Lime Manufacturing, Air Pollution Engineering Manual, Buonicore,Anthony J. and Wayne T. Davis (eds.), Air and Waste Management Association, Van NostrandReinhold, New York. 1992.

4. J. S. Kinsey, Lime And Cement Industry--Source Category Report, Volume I: Lime Industry,EPA-600/7-86-031, U. S. Environmental Protection Agency, Cincinnati, OH, September 1986.

5. M. Miller, Lime, Minerals Yearbook, Volume I, Metals and Minerals, Bureau of Mines, U.S.Department of the Interior, Washington, D.C., 1991.

6. Written communication from J. Bowers, Chemical Lime Group, Fort Worth, TX, to R. Marinshaw,Midwest Research Institute, Cary, NC, October 28, 1992.

7. Written communication from A. Seeger, Morgan, Lewis & Bockius, to R. Myers,U. S. Environmental Protection Agency, RTP, NC, November 3, 1993.

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3. GENERAL DATA REVIEW AND ANALYSIS

3.1 LITERATURE SEARCH AND SCREENING

Data for this investigation were obtained from a number of sources within the Office of AirQuality Planning and Standards (OAQPS) and from outside organizations. The AP-42 background fileslocated in the Emission Inventory Branch (EIB) were reviewed for information on the industry,processes, and emissions. The Crosswalk/Air Toxic Emission Factor Data Base Management System(XATEF) and VOC/PM Speciation Data Base Management System (SPECIATE) were searched by SCCfor identification of the potential pollutants emitted and emission factors for those pollutants. A generalsearch of the Air CHIEF CD-ROM also was conducted to supplement the information from these twodata bases.

Information on the industry, including number of plants, plant location, and annual productioncapacities, was obtained from the Minerals Yearbook, Census of Minerals, Census of Manufacturers, andother sources. The Aerometric Information Retrieval System (AIRS) data base also was searched fordata on the number of plants, plant locations, and estimated annual emissions of criteria pollutants.

A number of sources of information were investigated specifically for emission test reports anddata. A search of the Test Method Storage and Retrieval (TSAR) data base was conducted to identifytest reports for sources within the lime manufacturing industry. Copies of these test reports wereobtained from the files of the Emission Measurement Branch (EMB). The EPA library was searched foradditional test reports. A list of plants that have been tested within the past 5 years was compiled fromthe AIRS data base. Using this information and information obtained on plant location from theMinerals Yearbook, Census of Manufacturers, Census of Minerals, State and Regional offices werecontacted about the availability of test reports. However, the information obtained from these officeswas limited. Publications lists from the Office of Research and Development (ORD) and ControlTechnology Center (CTC) were also searched for reports on emissions from the lime manufacturingindustry. In addition, the National Lime Association was contacted for assistance in obtaininginformation about the industry and emissions.

To screen out unusable test reports, documents, and information from which emission factorscould not be developed, the following general criteria were used.

1. Emission data must be from a primary reference.

a. Source testing must be from a referenced study that does not reiterate information fromprevious studies.

b. The document must constitute the original source of test data. For example, a technical paperwas not included if the original study was contained in the previous document. If the exact source of thedata could not be determined, the document was eliminated.

2. The referenced study must contain test results based on more than one test run.

3. The report must contain sufficient data to evaluate the testing procedures and source operatingconditions (e.g., one-page reports were generally rejected).

14

A final set of reference materials was compiled after a thorough review of the pertinent reports,documents, and information according to these criteria.

3.2 EMISSION DATA QUALITY RATING SYSTEM

As part of the analysis of the emission data, the quantity and quality of the information containedin the final set of reference documents were evaluated. The following data were excluded fromconsideration:

1. Test series averages reported in units that cannot be converted to the selected reporting units;

2. Test series representing incompatible test methods (i.e., comparison of EPA Method 5 fronthalf with EPA Method 5 front and back half);

3. Test series of controlled emissions for which the control device is not specified;

4. Test series in which the source process is not clearly identified and described; and

5. Test series in which it is not clear whether the emissions were measured before or after thecontrol device.

Test data sets that were not excluded were assigned a quality rating. The rating system used wasthat specified by EIB for preparing AP-42 sections. The data were rated as follows.

A--Multiple tests that were performed on the same source using sound methodology and reportedin enough detail for adequate validation. These tests do not necessarily conform to the methodologyspecified in EPA reference test methods, although these methods were used as a guide for themethodology actually used.

B--Tests that were performed by a generally sound methodology but lack enough detail foradequate validation.

C--Tests that were based on an untested or new methodology or that lacked a significant amountof background data.

D--Tests that were based on a generally unacceptable method but may provide anorder-of-magnitude value for the source.

The following criteria were used to evaluate source test reports for sound methodology andadequate detail.

1. Source operation. The manner in which the source was operated is well documented in thereport. The source was operating within typical parameters during the test.

2. Sampling and analysis procedures. The sampling and analysis procedures conformed to agenerally acceptable methodology. If actual procedures deviated from accepted methods, the deviationsare well documented. When this occurred, an evaluation was made of the extent to which suchalternative procedures could influence the test results.

15

3. Sampling and process data. Adequate sampling and process data are documented in thereport, and any variations in the sampling and process operation are noted. If a large spread between testresults cannot be explained by information contained in the test report, the data are suspect and are givena lower rating.

4. Data analysis and calculations. The test reports contain original raw data sheets. Thenomenclature and equations used were compared to those (if any) specified by EPA to establishequivalency. The depth of review of the calculations was dictated by the reviewer's confidence in theability and conscientiousness of the tester, which in turn was based on factors such as consistency ofresults and completeness of other areas of the test report.

3.3 EMISSION FACTOR QUALITY RATING SYSTEM

The quality of the emission factors developed from statistical analysis of the test data was ratedusing the following general criteria.

A--Excellent: Developed only from A-rated test data taken from many randomly chosenfacilities in the industry population. The source category is specific enough so that variability within thesource category population may be minimized.

B--Above average: Developed only from A-rated test data from a reasonable number offacilities. Although no specific bias is evident, it is not clear if the facilities tested represent a randomsample of the industries. The source category is specific enough so that variability within the sourcecategory population may be minimized.

C--Average: Developed only from A- and B-rated test data from a reasonable number offacilities. Although no specific bias is evident, it is not clear if the facilities tested represent a randomsample of the industry. In addition, the source category is specific enough so that variability within thesource category population may be minimized.

D--Below average: The emission factor was developed only from A- and B-rated test data from asmall number of facilities, and there is reason to suspect that these facilities do not represent a randomsample of the industry. There also may be evidence of variability within the source category population. Limitations on the use of the emission factor are noted in the emission factor table.

E--Poor: The emission factor was developed from C- and D-rated test data, and there is reason tosuspect that the facilities tested do not represent a random sample of the industry. There also may beevidence of variability within the source category population. Limitations on the use of these factors arealways noted.

The use of these criteria is somewhat subjective and depends to an extent upon the individualreviewer. Details of the rating of each candidate emission factor are provided in Chapter 4 of this report.


1. Technical Procedures for Developing AP-42 Emission Factors and Preparing AP-42 Sections,EPA-454/B-93-050, Office of Air Quality Planning and Standards, U. S. Environmental ProtectionAgency, Research Triangle Park, NC, October 1993.

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4.0 AP-42 SECTION DEVELOPMENT

4.1 REVISION OF SECTION NARRATIVE

The section narrative was expanded to include a description of the parallel flow regenerative limekiln, also known as the Maertz kiln, which had not been addressed in the previous version of AP-42. Other than minor editorial changes, no other changes were made to the section narrative.

4.2 POLLUTANT EMISSION FACTOR DEVELOPMENT

A total of 50 documents were reviewed in the process of developing emission factors for thisrevision to AP-42. The majority of the data for this revision were obtained from the background file forthe AP-42 section. In addition, five new test reports (References 23 through 26 and Reference 50) thatwere not in the background file were reviewed. Table 4-1

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TABLE 4-1. SUMMARY OF EMISSION TEST REPORTS USED TO DEVELOP EMISSION FACTORS

Company name Plant location Sources tested Pollutants Year Ref.

J. M. Brenner Lancaster, PA Primary crusher, screens, PM 1974 2 hammermill, final sizing screens

Marblehead Lime Bellefonte, PA Rotary kiln PM 1975 3

J. E. Baker Millersville, OH Rotary kiln PM, CO 1975 5 2

Virginia Lime Ripplemead, VA Rotary kiln PM, SO , 1975 6 2NO , CO,xCO2

Pfizer, Inc. Gibsonburg, OH Rotary kiln PM 1980 7 Materials transferProduct loading

Standard Lime Woodville, OH Rotary kiln PM, NO , 1975 8 xCO2

Dow Chemical Freeport, TX Rotary kiln PM, NO , 1974 9 xCO2

J. E. Baker Millersville, OH Rotary kiln PM, SO , 1974 10 2SO3, CO2

J. E. Baker Millersville, OH Rotary kiln PM, SO , 1975 11 2CO2

Paul Lime Plant Millersville, OH Rotary kiln PM 1975 12

U.S. Lime Nelson, AZ Rotary kiln PM, SO , 1975 13 2CO2

Allied Products Montevallo, AL Rotary kiln PM, SO , 1975 14 2NO , CO,xCO2

Martin-Marietta Calera, AL Rotary kiln PM, SO , 1975 152NO , CO,xCO2

Atmospheric hydrator PM

Plant No. 1 Rotary kiln PM, CO 1977 16 2



U.S. Lime City of Industry, CA Atmospheric hydrator PM, CO 1974 19 2

National Lime and Stone Carey, OH Calcimatic kiln PM, NO , 1974 20 xCO2

Cooler PM, CO2

Martin-Marietta Woodville, OH Rotary kiln SO , CO 1976 21 2 2

Rotary kiln with preheater CO2

J. E. Baker Millersville, OH Rotary kiln SO , CO, 1975 22 2CO2

Allied Products Alabaster, AL Rotary kiln PM, CO 1990 23 2


Dravo Lime Saginaw, AL Rotary kiln PM, CO 1986 25 2

TABLE 4-1. (continued)


18

Dravo Lime Saginaw, AL Rotary kiln PM, SO , 1991 26 2NO ,xCO2

Paul Lime Co. Douglas, AZ Rotary kiln PM 1972 27

Bethlehem Mines Annville, PA Rotary kiln PM, SO , 1974 28 2NO ,xCO, CO2

Marblehead Lime Gary, IN Rotary kiln PM, SO , 1974 29 2NO ,xCO, CO2


J. E. Baker Millersville, OH Rotary kiln PM 1975 31

Chemstar Lime Co. Bancroft, ID Six raw material processing sources PM 1993 50

Parallel flow regenerative kiln PM, SO ,2NO , COx

19

lists plant name, location, test date, sources tested, and pollutants measured for each of the primaryreferences used to develop emission factors for this revision to Section 11.15. Table 4-2

20

TABLE 4-2. REFERENCES NOT USED TO DEVELOP EMISSION FACTORS

ReferenceNo. Reason for rejection

4 All test runs anisokinetic (140 to 190 percent).

32 Process rates labeled as incorrect.

33 Process rates labeled as incorrect.

34 Process data not included.

35 Test method, emission data units not specified.

36 Incomplete data, contradictory data.







43 All test runs anisokinetic (71, 87, 56, 135 percent).

44 Test data not provided.

45 Test data not provided.

46 All test runs anisokinetic (119 to 130 percent).



49 Test was not conducted on lime manufacturing source.

21

lists the references that were not used for this revision and indicates why emission factors were notdeveloped from the data presented in those documents. Emission factors were developed for emissionsof filterable PM, condensible inorganic PM, condensible organic PM, PM-10, CO, CO2, SO2, and NOx. Table 4-3 summarizes the data presented in each of the reports from which emission factors weredeveloped.

As has been the practice in previous versions of AP-42, the emission factors for lime kilnspresented in Table 4-3 are in units of mass of pollutant emitted in kg (lb) per mass of lime produced inMg (ton). Five of the 28 test reports from which lime kiln emission factors were developed providedprocess rates in terms of lime production; five reports provided process rates in terms of both stone feedand lime production; and the remaining 18 reports provided process rates on the basis of stone feed. Ofthe five reports that included both feed and production rates, the ratio of production to feed ranged from0.38 to 0.55 and averaged 0.48. Therefore, a production-to-feed ratio of 0.5 was used to convert feedrates to production rates for those test reports for which only feed rates are provided.

Two of the test reports (References 15 and 19) provide data on emissions from atmospherichydrators. Both of these reports provide feed and production data, and the emission factors are presentedin Table 4-3 in units of mass of pollutant per mass of hydrated lime produced. Emission factors for themechanical processing of limestone (crushing, screening, and grinding) are presented in Table 4-3 inunits of mass of pollutant emitted per mass of stone feed.

Particle size data have not been revised from the previous version of AP-42 because new data werenot available, and no problems were found with the methodology and analysis used to develop theparticle size data for the previous version of AP-42. A detailed discussion of how the particle size datawere developed for the section can be found in Reference 1, which is the background report for theprevious revision, dated October 1986. Table 4-4 summarizes the particle size data from Reference 1.

The following section describes each of the references used to develop emission factors forSection 11.15.

22

23

24

TABLE 4-3. SUMMARY OF TEST DATA FOR LIME MANUFACTURING

Source Control PollutantaNo. ofruns

EF range, kg/Mg(lb/ton)b

EF average, kg/Mg(lb/ton)b

Datarating

Ref.No.

Rotary kiln (coal-fired)

None PM, filterable 5 130-200(270-410)

170(330)

A 6

Rotary kiln(coal-fired)


190(370)

A 7


Large-diametercyclone

PM, filterable 15 34-80(68-160)

60(120)

A 7


Large- diametercyclone

PM, filterable 2 97-110(190-210)

100(200)

C 8


Fabric filter PM, filterable 12 0.026-0.072(0.052-0.14)

0.049(0.097)

A 7



0.28(0.56)

C 28



0.41 (0.83)

D 17


Fabric filter PM, filterable 2 0.55-0.56(1.1)

0.55(1.1)

D 3



0.98 (2.0)

D 16



0.51(1.0)

D 18



0.087 (0.17)

C 15



0.13(0.25)

B 26


ESP PM, filterable 16 2.1-6.1(4.4-12.1)

4.3(8.5)

A 7

Rotary kiln (coal-fired)c

Venturi scrubber PM, filterable 3 0.30-0.51(0.60-1.0)

0.46(0.93)

D 31

Rotary kiln(coal-fired)c

Venturi scrubber PM, filterable 3 2.4-6.5(4.7-13)

4.1(8.2)

C 11

Rotary kiln(coal-fired)d


2.0(4.0)

C 10



1.2(2.4)

B 5



0.55 (1.1)

B 24

Rotary kiln(coal-fired)e


0.41 (0.82)

B 23


None PM,condensibleinorganic

3 0.57-1.5(1.1-2.9)

0.90(1.8)

C 6



PM,condensibleinorganic

2 0.30-0.57(0.61-1.1)

0.43(0.87)

C 8


Fabric filter PM,condensibleinorganic

2 0.077-0.080(0.16-0.16)

0.079(0.16)

C 15





Datarating

Ref.No.

25



3 0.032-.039(0.064-0.079)

0.035(0.070)

C 28



6 0.13-0.38(0.25-0.75)

0.22 (0.45)

D 16



3 0.026-0.10(0.052-0.21)

0.058(0.12)

D 18



6 0.067-1.4(0.13-2.8)

0.45 (0.90)

D 17



2 0.14-0.18(0.29-0.36)

0.16(0.33)

D 3


Venturi scrubber PM,condensibleinorganic

3 0.027-0.20(0.054-0.40)

0.12(0.24)

B 5



3 0.20-0.47(0.39-0.93)

0.33 (0.65)

C 10



3 0.030-0.090(0.059-0.18)

0.055 (0.11)

C 11



3 0.20-0.27(0.41-0.54)

0.24(0.48)

D 31


None PM,condensibleorganic

3 0.32-0.81(0.63-1.6)

0.51(1.0)

C 6

Rotary kiln (coal-fired)d

None PM, filterableandcondensibleinorganic

3 100-160(200-330)

120(250)

C 5


None SO2 5 1.1-3.1(2.2-6.2)

2.3 (4.6)

B 15


None SO2 3 2.7-3.8(4.3-7.7)

3.1(6.2)

A 6


Fabric filter SO2 3 0.11-0.26(0.22-0.51)

0.18(0.37)

C 28


Fabric filter SO2 5 1.1-3.1(2.2-6.2)

2.3 (4.6)

B 15


Fabric filter SO2 1f 5.3(11)

5.3(11)

D 15


Fabric filter SO2 3 0.0044-0.0066(0.0087-0.011)

0.0066 (0.013)

B 26


Venturi scrubber SO2 3 0.25-0.65(0.50-1.3)

0.40(0.79)

C 10





Datarating

Ref.No.

26


Venturi scrubber SO2 3 15-19(30-38)

17(34)

D 11


Settling chamber SO2 6 2.1-9.2(4.2-18)

5.8(12)

C 22


Settlingchamber/wetscrubber

SO2 5 0.049-0.20(0.10-0.40)

0.076(0.15)

B 22



SO2 6 0.17-0.30(0.33-0.64)

0.23(0.45)

B 22


Settling chamber SO2 6 5.2-6.6(10-13)

5.9 (12)

C 22


None NOx 3 0.20-1.0(0.40-2.0)

0.56(1.1)

A 8


None NOx 12 0.73-2.3(1.5-4.5)

1.6(3.2)

A 6


Fabric filter NOx 3 1.7-2.0(3.3-3.6)

1.8(3.6)

C 28



2.7(5.3)

B 15



1.1 (2.1)

B 26


None CO 2 25-27(50-54)

26(52)

D 6


Fabric filter CO 4 0.11-0.83(0.22-1.7)

0.38 (0.76)

B 15


Fabric filter CO 3 0.046-0.088(0.093-0.18)

0.061(0.12)

D 28


Settling chamber/wet scrubber

CO 8 0.53-4.0(1.1-8.1)

1.4(2.7)

C 22


Settling chamber CO 4 0.25-0.55(0.49-1.1)

0.45(0.90)

C 22


None CO2 2 2,200-2,200(4,500-4,500)

2,200 (4,500)

C 8


None CO2 1 2,100-2,800(4,300-5,500)

2,500(4,900)

C 5


None CO2 5 710-1,500(1,400-3,000)

1,300(2,500)

A 6


Fabric filter CO2 3 1,200-1,300(2,400-2,700)

1,300(2,500)

C 28


Fabric filter CO2 3 not available 1,500(3,100)

C 18


Fabric filter CO2 3 not available 970 (1,900)

D 17


Fabric filter CO2 2 1,100-1,100(2,100-2,200)

1,100 (2,200)

C 15





Datarating

Ref.No.

27


Fabric filter CO2 6 1,500-1,600(3,100-3,300)

1,600 (3,200)

D 16


Fabric filter CO2 3 1,400-1,500(2,700-3,100)

1,500(3,000)

B 26


Venturi scrubber CO2 3 1,600-1,800(3,200-3,600)

1,700(3,400)

B 24



1,500 (3,000)

B 23


Venturi scrubber CO2 1 2,500(4,900)

2,500(4,900)

B 5



2,500 (5,000)

C 10


Settling chamber CO2 4 1,100-1,700(2,100-3,400)

1,400(2,700)

B 22


Settling chamber CO2 10 360-1,300(730-2,500)

940(1,900)

B 21



CO2 4 1,900-2,300(3,900-4,600)

2,100(4,200)

B 22


Settling chamber CO2 5 1,700(3,300-3,400)

1,700(3,400)

B 22


Venturi scrubber SO3 3 0.10-0.12 (0.20-0.24)

0.11(0.21)

C 10

Rotary kiln(gas-fired)


0.086(0.17)

C 9


Gravel bed filter PM, filterable 3 0.38-0.50(0.76-1.0)

0.44 (0.87)

C 12



0.57(1.1)

D 27


ESP PM,condensibleinorganic

2 0.085-0.13(0.17-0.27)

0.11(0.22)

C 9


Gravel bed filter PM,condensibleinorganic

3 0.0036-0.051(0.0072-0.10)

0.022 (0.045)

D 12



2 0.45-0.46(0.90-0.92)

0.46(0.91)

D 27


ESP NOx 3 1.4-2.1(2.8-4.2)

1.7(3.5)

C 9


ESP CO 3 0.29-2.6(0.59-5.1)

1.1(2.2)

C 9

Rotary kiln(50/50 coal-, gas-fired)e


40(80)

D 30





Datarating

Ref.No.

28

Rotary kiln(60% coal-, 40%gas-fired)

Multiclone/venturiscrubber

PM, filterable 3 0.35-0.48(0.69-0.97)

0.44(0.87)

B 14



0.33(0.65)

D 30




3 0.032-0.051(0.064-0.10)

0.041(0.082)

B 14


None SO2 1g 1.4-2.7(2.0-5.5)

1.9(3.9)

D 14



NOx 3 1.2-1.6(2.3-3.2)

1.4(2.7)

B 14



CO 3 0.14-0.82(0.28-1.6)

0.41 (0.83)

B 14



CO2 3 1,600-1,600(3,200-3,300)

1,600 (3,200)

B 14


Venturi scrubber CO2 1 690(1,400)

690(1,400)

D 30

Rotary kiln(70% coke-, 30%coal-fired)


0.83 (1.7)

B 25



1,500 (3,000)

B 25

Rotary kiln withpreheater(coal-fired)

Multiclone PM, filterable 2 19-65(38-130)

42(84)

C 8



0.59(1.2)

C 13


Multiclone/waterspray/fabric filter

PM, filterable 6 0.30-0.72(0.61-1.4)

0.56 (1.1)

C 29


Multiclone PM,condensibleinorganic

2 0.039-0.042(0.078-0.083)

0.040(0.081)

C 8

Rotary kiln withpreheater (coal-fired)



6 0.40-0.68(0.79-1.4)

0.57(1.1)

C 29



PM,condensibleorganic

6 0.0099-0.14(0.020-0.27)

0.076(0.15)

C 29





Datarating

Ref.No.

29


Gravel bed filter SO2 2 0.026-0.63(0.052-1.3)

0.33 (0.65)

C 13


Settling chamber/fabric filter

SO2 6 1.2-2.8(2.4-5.6)

1.9(3.9)

C 21



SO2 6 3.0-3.9(6.0-7.8)

3.2(6.4)

C 29


None NOx 3 2.2-2.3(4.4-4.6)

2.3(4.5)

A 8



NOx 12 0.83-2.3(1.7-4.5)

1.1(2.2)

C 29



CO 3 0.24-8.7(0.48-17)

3.2(6.3)

D 29


None CO2 2 1,400-1,400(2,800-2,800)

1,400(2,800)

C 8


Gravel bed filter CO2 2 2,500-2,600(4,900-5,300)

2,500(5,100)

C 13



1,600(3,200)

B 21


Settling chamber CO2 7 600-1,100(1,200-2,300)

840 (1,700)

B 21



CO2 3 1,100-1,200(2,200-2,400)

1,100 (2,300)

B 21



CO2 6 1,600-1,900(3,200-3,800)

1,700(3,400)

C 29

Calcimatic kiln(gas-fired)


88(180)

D 20


None PM, filterable 2 6.8-7.0(14-14)

7 (14)

D 20



2 0.036-0.10(0.072-0.19)

0.066(0.13)

D 20



2 0.18-0.23(0.37-0.46)

0.21(0.41)

C 20


None NOx 5 0.039-0.095(0.079-0.19)

0.076 (0.15)

A 20





Datarating

Ref.No.

30


None CO2 2 2,000(4,000-4,100)

2,000(4,000)

C 20


None CO2 2 670-690(1,300-1,400)

680(1,400)

C 20

Parallel flowregenerative kiln(gas-fired)

Fabric filter PM, filterable 3 0.022-0.028 (0.044-0.056)

0.026(0.051)

A 50


Fabric filter SO2 3 0.00040-0.00080(0.00079-0.0016)

0.00060(0.0012)

A 50



0.12(0.024)

A 50


Fabric filter CO 3 0.21-0.24(0.41-0.48)

0.23(0.45)

A 50

Atmospherichydrator

Wet scrubber PM, filterable 2 0.026-0.043(0.052-0.086)

0.033(0.067)

B 19

Atmospherichydrator


0.087 (0.17)

C 15

Atmospherichydrator

Wet scrubber PM,condensibleinorganic

2 0.0046-0.0091(0.0091-0.018)

0.0067(0.013)

B 19

Atmospherichydrator


3 0.010-0.079(0.0071-0.021)

0.0069 (0.014)

C 15

Cooler None PM, filterable 2 2.4-4.5(4.7-9.0)

3.4(6.8)

C 20

Cooler None PM,condensibleinorganic

2 0.0049-0.018(0.010-0.036)

0.011(0.023)

C 20

Cooler None CO2 2 3.8-4.0(7.6-8.0)

3.9(7.8)

C 20

Final sizingscreens

Fabric filter PM, filterable 1 0.0012(0.0023)

0.0012(0.0023)

unrated 2

Primary crusher None PM, filterable 2 0.0076-0.0090(0.015-0.0018)

0.0083(0.017)

C 2

Primary crusher,screen, andhammermill


0.00044(0.00089)

C 2

Scalping screenand hammermill

None PM, filterable 2 0.00029-0.62(0.00058-1.2)

0.31(0.62)

D 2

Primary crushingh Fabric filter PM, filterable 3 0.00019-0.00023(0.00039-0.00046)

0.00021(0.00043)

A 50

Primaryscreeningi


0.00030(0.00061)

A 50





Datarating

Ref.No.

31

Crushed materialconveyor transferj

Fabric filter PM, filterable 6 (2.8x10-5-8.1x10-5)(5.6x10-5-0.00016)

4.4x10-5

(8.8x10-5)A 50

Secondary andtertiary screeningk

Fabric filter PM, filterable 3 4.8x10-5-4.0x10-5

(9.5x10-5-0.00016)6.5x10-5

(0.00013)A 50

Material transferand drop points


1.1(2.2)

C 7

Fugitive, productloading (enclosedtruck)


0.31(0.61)

A 7

Fugitive, productloading (opentruck)


0.75(1.50)

B 7

aFilterable PM is that PM collected on or prior to the filter for an EPA Method 5 (or equivalent) sampling train. Condensible PMis that PM collected in the impinger portion of a PM sampling train and analyzed by EPA Method 202. Emission factors forcondensible PM include both organic and inorganic condensible PM. Total PM is that PM collected in the entire sampling trainand analyzed by Methods 5 and 202.

bEmission factors for kilns, coolers, preheaters, and hydrators in units of mass of pollutant emitted per mass of lime produced;emission factors for crushing, screening, grinding, and loading in units of mass of pollutant emitted per mass of stone/lime feed.

cTests conducted on the this kiln are also documented in other references as indicated.dTests conducted on the this kiln are also documented in other references as indicated.eTests conducted on the this kiln are also documented in other references as indicated.fMultiple CEM readings.gA total of 30 CEM readings over a 4-hour period.hIncludes scalping screen, scalping screen discharges, primary crusher, primary crusher discharges, and ore discharge.iIncludes primary screening, including the screen feed, screen discharge, and surge bin discharge.jBased on average of three runs each of emissions from two conveyor transfer points on the conveyor from the primary crusher tothe primary stockpile.

kBased on sum of emissions from two emission points that include conveyor transfer point for the primary stockpile underflow tothe secondary screen, secondary screen, tertiary screen, and tertiary screen discharge.

32

TABLE 4-4. AVERAGE PARTICLE SIZE DISTRIBUTION FOR ROTARY LIME KILNSa

Particle size,Fm

Cumulative mass percent less than stated particle size

Uncontrolledrotary kiln

Rotary kiln withmulticlone

Rotary kiln withESP

Rotary kiln withfabric filter

2.5 1.4 6.1 14 27

5.0 2.9 9.8 ND ND

10.0 12 16 50 55

15.0 31 23 62 73

20.0 ND 31 ND ND

ND = no data available.aReference 1, Table 4-28; based on A- and C-rated particle size data.

33

4.2.1 Review of Specific Data Sets

4.2.1.1 Reference 1. Reference 1 is the background report used for the 1986 revision to theAP-42 section on lime manufacturing. Reference 1 documents the development of filterable PMemission factors and particle size distribution for various lime manufacturing sources. All of the primarysources used to develop the PM emission factors presented in Reference 1 were used in this proposedrevision to update the filterable PM emission factors. The particle size data presented in Reference 1were retained without change in this revision to AP-42.

4.2.1.2 Reference 2. This report documents measurements of controlled and uncontrolledfilterable PM, condensible inorganic PM, and condensible organic PM emissions from limestonecrushing operations. The sources tested included a primary crusher, final sizing screens, and acombination of scalping screens and a hammermill. The tests were conducted in 1974 and weresponsored by EPA as part of the information-gathering effort for an NSPS for stone crushing. Emissionsfrom the primary crusher, scalping screens, and hammermill are controlled with a common fabric filter. Emissions from the final sizing screens are controlled with a separate fabric filter.

Method 5 (front and back halves) was used to measure PM emissions. Although back half PMcatches are reported in the results, these processes operate at ambient temperature and should not emitcondensible PM. Therefore, it is assumed that the back half catches are the result of an anomaly in thesampling and analytical procedures used. The test report does not include adequate information todetermine the origin of this apparent anomaly.

Three runs were conducted on the outlets of the two fabric filters, but only two inlet runs wereconducted. Several problems with the tests were reported. The final sizing screen fabric filter outlet datawere discarded because the outlet flow rate was measured to be twice the inlet flow rate. Negative filterweights were reported for one of the runs on the primary crusher/scalping screens/hammermill fabricfilter outlet and for two of the runs on the final sizing screen fabric filter outlet. In addition, for the teston the scalping screen/hammermill fabric filter outlet, emission rates varied by more than three orders ofmagnitude. Emission factors were developed for filterable PM emissions from all of the sources tested.

The emission factors for uncontrolled emissions from the primary crusher are rated C becauseonly two test runs were conducted, and the emission factors for uncontrolled emissions from the scalpingscreens/hammermill are rated D because only two runs were conducted and the filterable PM data variedby more than three orders of magnitude. The emission factors for controlled emissions from thecombination of primary crusher, scalping screens, and hammermill are rated C because only two runswere valid. The filterable PM emission factor for controlled emissions from the final sizing screens isunrated because only one test run was valid.

4.2.1.3 Reference 3. This report documents measurements of controlled PM emissions fromthree rotary kilns. The tests were conducted in July 1975 to supplement a compliance test sponsored bythe Pennsylvania Department of Environmental Resources. Process rates were provided on the basis oflime production.

Particulate matter emissions from these kilns were controlled by two common fabric filters thatcomprised six compartments each. The fabric filters were arranged in parallel so that the emissions fromthe three kilns were routed simultaneously to both fabric filters. The emissions were sampled in one ofthe six compartments of each fabric filter. The emission data from each of the two compartments thatwere sampled were multiplied by a factor of six to obtain an estimate of total emissions from each fabric

34

filter. Two test runs were conducted, and filterable and condensible inorganic PM emissions weremeasured. Emission factors were developed for controlled filterable PM and condensible inorganic PMemissions.

The data in this report were rated D. The test report generally was lacking in documentation, andthe test method was not specified. Furthermore, only two test runs were conducted, and only onecompartment of each fabric filter was sampled.

4.2.1.4 Reference 5. This report documents measurements of controlled PM and CO2 emissionsfrom a coal-fired rotary lime kiln. Particulate emissions from the kiln were controlled by a venturiscrubber. The tests were performed in February 1975 to determine whether particulate emissions fromthe kiln were in compliance with State regulations.

Process information was limited. Feed and production rates were not available for each test run,but the average feed rate was provided. Therefore, the emission factors are based on the average feedrate. In developing emission factors from the data, it was assumed that production rates were one-half offeed rates.

Three runs were conducted at both the inlet and outlet of the venturi scrubber. The samplinggenerally was in accordance with Method 5. However, the inlet sampling train was modified by placingthe glass fiber filter behind the impingers. Both the impinger and filter contents were dried at 110EC(230EF) and weighed to determine the weight of the PM catch. Therefore, the measured inlet PMemission rate consists of both filterable and condensible inorganic PM emission rates. The outletsampling train was in accordance with EPA Method 5. Orsat was used to make one measurement of CO2

concentrations in the exhaust at both the inlet and outlet of the venturi scrubber.

From the inlet PM data, emission factors were developed for combined filterable and condensibleinorganic PM. The outlet PM data were used to develop emission factors for controlled filterable PMand condensible inorganic PM emissions. In addition, an emission factor was developed for CO2

emissions.

A rating of C was assigned to the inlet PM data because the tests conducted at the inlet variedsignificantly from standard sampling protocol. The outlet data were rated B because standard samplingprotocol was followed. The test methods were sound and no problems were reported, but the reportlacked adequate process documentation to warrant a higher rating. The CO2 data are rated C becauseonly two measurement were made.

4.2.1.5 Reference 6. This report documents measurements of filterable PM, condensibleinorganic PM, condensible organic PM, CO, SO2, NOx, and particle size distribution on a coal-firedrotary lime kiln. In addition, data on CO2 emissions were generated from the PM sampling runs. At thetime of the test, the kiln was not equipped with emission control equipment. The test was conductedfrom April 29 to May 3, 1975 and was sponsored by EPA.

Process rates for this test are provided on the basis of feed rate. However, the report states thathistorical data from the facility showed that for every two tons of feed, one ton of product was produced. Therefore, a feed to production ratio of 0.5 was used to develop emission factors on the basis of limeproduction.

35

The following test methods were used: Method 5 for filterable PM, Method 10 for CO, Method6 for SO2, Method 7 for NOx, and a Brink impactor for particle size emissions data. The back half of theMethod 5 sampling train also was analyzed for condensible PM. The analysis included an ether-chloroform extraction to quantify condensible organic emissions. However, the analytical procedureswere not described in detail. Five runs were originally conducted to determine PM emissions, but two ofthese were not completed due to sampling difficulties. These two runs, however, provided complete CO2

analyses. Thus, data from all five tests were used to determine average CO2 emissions. Because ofunidentified problems with the analyzer, CO emission data are reported for only two of the five runs, andthe results of the two runs reported are suspect.

As stated previously, the particle size data in Reference 6 were evaluated for the 1986 update ofAP-42 Section 11.15 and were not reevaluated as part of this revision. However, the particle size datawere used to develop the PM-10 emission factors presented in this revision to Section 11.15. Only twoof the PM runs included an analysis of the back half of the Method 5 sampling train.

The sampling and analytical methods for filterable PM, SO2, and NOx followed EPA procedures,and sufficient data and documentation are presented for adequate validation. Data for the filterable PM,SO2, and NOx from this reference were assigned an A rating because the sampling and analysis methodswere sound, and the documentation was adequate. Because the Method 5 back-half analysis lackedsufficient documentation, the condensible inorganic and organic PM data are rated C. Due to theproblems with the CO test, the CO data are rated D.

As discussed in Reference 1, the Brink impactor, which was used to collect the particle size data,is not well suited for sampling uncontrolled emissions that are characterized by substantial quantities oflarge particles. In addition, the cutpoint of the inertial impactor was not calibrated. Therefore, theparticle size data are rated C.

4.2.1.6 Reference 7. This test report documents measurements of controlled and uncontrolledPM emissions from two rotary kilns. The emissions from one kiln (Kiln 6) were controlled by acombination of a cyclone and a fabric filter, and the emissions from the second kiln (Kiln 7) werecontrolled by an ESP. Uncontrolled PM emissions from a dust collection system also were measured. The dust collection system consists of several hoods located over conveyor transfer and drop points. Particulate matter emissions are collected in the hoods and ducted to a common fabric filter. In addition,fugitive PM emissions were tested at two product loading areas. The tests were sponsored by EPA andconducted from October 15, 1980 through January 12, 1981. The results of analyses for total PM andparticle size distributions are presented for all sampling locations. Process rates were provided on thebasis of lime production.

Sampling of the two kilns was conducted in accordance with EPA Method 5. Fifteen runs wereconducted on Kiln 6 at the fabric filter inlet, downstream of the cyclone, and 12 runs were conducted atthe fabric filter outlet. Sixteen runs were conducted on Kiln 7 at both the inlet and outlet of the ESP. Particle size was measured using a cascade impactor with a cyclone preseparator.

Emissions from the dust collection system also were sampled in accordance with EPA Method 5. The emission factors were reported as total PM emissions per ton of product. Fifteen test runs wereconducted on a central dust collection duct, which transports dust collected at 13 product transfer anddrop points to a fabric filter. The inlet and outlet to the fabric filter were not tested because dustcollected from other product operations also was ducted to the fabric filter. The report does not providedetails on the design of the collection system. Therefore, it is not possible to determine the capture

36

efficiency of the hoods or to determine if face air velocities for the hoods are typical. As a result, it is notpossible to determine if the test results are typical, biased high due to induced wind erosion by theventilation system, or biased low due to poor capture efficiency.

Fugitive PM emissions from two product loading bays also were measured. Five test runs fortotal suspended particulates (< 30F), inhalable particulates (< 15F), and fine particulates (< 2.5F) wereconducted during product loading operations using a standard high volume air sampler (Hi-Vol), two Hi-Vols with Andersen size-selective inlet (SSI) devices, and two Hi-Vols with cyclones and impactors. Two of the runs were conducted on open trucks, and three runs were conducted on enclosed trucks. Background PM concentrations were tested using a Hi-Vol, a Hi-Vol with an SSI and a Hi-Vol with acyclone and an impactor.

The PM emission and particle size data for the tests on the kilns were rated A because standardsampling protocol was followed and no problems were reported. The PM emission data for producttransfer and drop points are rated C due to the uncertainty in the representativeness of the data, asexplained previously. The emission data for loading enclosed trucks also are rated A; the emission datafor loading open trucks are rated B because only two runs were conducted.

4.2.1.7 Reference 8. This test was conducted on the exhaust of two coal-fired rotary kilns tomeasure uncontrolled emissions of PM and NOx and to obtain particle size data. The test was conductedin December 1975 and was sponsored by EPA. Process rates were provided on the basis of both stonefeed and lime production.

The sampling locations for each kiln were located downstream of a cyclone and upstream of afabric filter. At each location, two runs were conducted to measure filterable PM, condensible inorganicPM, and CO2 emissions, and three runs to quantify emissions of NOx. Method 5 was used to measurePM emissions, and Method 7 was used to quantify emissions of NOx. Carbon dioxide concentrations inthe exhaust stream were measured using Orsat, and cascade impactors were used for the particle sizedetermination.

This emission test is well documented, and sampling and analytical methods follow EPAprotocol. However, because only two runs were conducted at each sampling location, the PM and CO2

data were rated C. The data for NOx emissions are rated A. The particle size data are rated D becauseonly a single test run was conducted on each kiln.

4.2.1.8 Reference 9. This report documents measurements of PM, CO, SO2, NOx, and CO2

emissions from three natural gas-fired rotary kilns equipped with ESP's. The emission test wassponsored by EPA to provide information for establishing an NSPS for lime kilns. The test wasconducted from April 30 to May 3, 1974.

Emissions from the three kilns feed into a common plenum that is designed to distribute theexhaust gas evenly to a pair of ESP's. During the test, one of the kilns was not operating. The outlet ofeach ESP is ducted to a separate stack, from which all samples were taken. The north stack was testedfor filterable and condensible PM, CO, and SO2 emissions using Methods 5, 10, and 6, respectively; thesouth stack was tested for filterable and condensible PM, CO, and NOx emissions by Methods 5, 10, and7, respectively. The Method 6 sampling train was modified by adding a dry impinger between theisopropanol bubbler and the first peroxide impinger. Carbon dioxide concentrations were measured byOrsat. Three runs were conducted on each stack.

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The results of the first PM run were not valid because the probe was improperly positionedduring sampling. The third Method 10 run on both stacks indicated CO concentrations that were 5 to 10times the concentrations recorded during the first two runs. No explanation for this inconsistency in theCO emission data is provided in the report. Finally, all CO2 readings are reported as invalid due tosystem leaks.

Emission factors were developed for filterable PM, condensible inorganic PM, CO, and NOx

emissions. Emission factors were not developed for CO2 due to the problem noted above. In addition,emission factors were not developed for SO2 emissions because SO2 was not detected in any of thesamples collected. Process rates are provided in the report on the basis of raw material feed. Theemission factors developed from the data are presented in units of mass of pollutant emitted per mass ofproduct, based on the assumption that production rates are one-half of feed rates.

The PM data are rated C because they are based on only two test runs and estimated productionrates. The CO data are rated C because of the inconsistency in emission rates. The NOx data are rated Cbecause only one of two stacks was tested, and the total emission rate was assumed to be twice theemission rate from the single stack that was tested.

4.2.1.9 Reference 10. This test report documents measurements of PM, SO2, and CO2 from acoal-fired rotary kiln and a cooler. The tests were conducted from May 21 to 23, 1974 by the facility aspart of a self-evaluation. Process rates are provided on the basis of both stone feed and lime production.

The exhaust from a product cooler was ducted to one of the stacks tested. Because the testreport did not specify how much of the exhaust was recovered for kiln combustion gas, an emissionfactor for this source could not be determined.

Three runs were performed to determine filterable and condensible inorganic PM, CO2, and SO2

emissions from the kiln. Test methods followed EPA protocol, but the report did not present raw field orlaboratory data, and the exact sampling locations were not specified. Because of the general lack ofdocumentation, the data from this reference were rated C.

4.2.1.10 Reference 11. This test report documents measurements of PM, SO2, and CO2

emissions from a coal-fired rotary kiln. The test was conducted in April 1975 and was sponsored by thefacility to analyze the exhaust of the venturi scrubber controlling emissions from the kiln. Process rateswere provided on the basis of feed; production rates were estimated as half of the feed rate.

Three runs were performed at the scrubber outlet to determine emissions of filterable andcondensible inorganic PM using Method 5 and emissions of SO2 using Method 6. For the SO2 test, onlyone run was conducted to determine stack gas flow rate. In addition, only a single CO2 measurement wasmade.

The report contained no raw data, provided little information about the process, and did notspecify the sampling location. For these reasons, the PM data from this report were rated C. The SO2

data are rated D due to the lack of documentation and the fact that only one flow rate measurement wasmade during the test. Emission factors were not developed for CO2 because only one CO2 measurementwas reported.

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4.2.1.11 Reference 12. This test was conducted to measure controlled PM emissions from a gas-fired rotary kiln. The test was performed on June 6, 1973 as part of a compliance test for the State ofArizona.

Emissions from the kiln are controlled by a cyclone and gravel bed filter combination. Threeruns were conducted on the gravel bed filter outlet using Method 5. However, the method forquantifying condensible inorganic PM emissions from the back half of the Method 5 sampling train is notdescribed in the report.

Process rates were provided on the basis of feed; production rates were estimated as half of thefeed rate. Emission factors were developed for emissions of filterable and condensible inorganic PM.

The filterable PM data are rated C due to the general lack of adequate documentation in thereport and the fact that production rates were estimated from feed rates. The condensible inorganic PMdata are rated D because the method is not described and because of the wide range in data (the emissionrate for Run 1 is reported as 13 times the emission rate for Run 3). It is unknown if the wide range indata is due to variations in emission rates or is due to problems with the test.

4.2.1.12 Reference 13. This test report documents measurements of controlled filterable PMand SO2 emissions from a coal-fired rotary kiln. The tests were conducted on May 6 and 7, 1975 as partof a compliance test. Emissions from the kiln are controlled with a gravel bed filter.

Three test runs were performed at the gravel bed filter outlet to determine the controlledfilterable PM emissions, and two runs were conducted to quantify SO2 emissions. Filterable PM and SO2

emissions were sampled using EPA Methods 5 and 6, respectively. Two measurements of CO2

concentrations were taken using Orsat.

Process rates were provided on the basis of feed; production rates were estimated as half of thefeed rate. Emission factors were developed for emissions of filterable and condensible inorganic PM.

The filterable PM data are rated C due to the general lack of adequate documentation in thereport and the fact that production rates were estimated from feed rates. The SO2 and CO2 emission dataare also rated C for the same reasons and because only two runs were conducted.

4.2.1.13 Reference 14. This test report documents measurements of filterable and condensiblePM, particle size distribution, CO, CO2, SO2, and NOx emissions. The test was conducted on a coal- andgas-fired rotary kiln in September 1975. The test was sponsored by EPA to collect data to establishstandards for new and substantially modified sources. Process rates were provided on the basis of feed;production rates were estimated as half of the feed rate.

The emissions from the kiln were controlled by a cyclone followed by a venturi scrubber. Method 5 was used to measure PM emissions, Method 6 was used to measure SO2 emissions, NOx

emissions were quantified using Method 7, Method 10 was used to measure CO emissions, and CO2

concentrations were measured using Orsat. A continuous emission monitor (CEM) also was used to take30 measurements of SO2 emissions over a 4-hour period. In addition, particle size was measured using acascade impactor with cyclone preseparator.

The scrubber inlet was sampled for three test runs for particle size distribution and SO2

concentrations. The outlet was sampled for three test runs for particle size distribution, filterable and

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condensible inorganic PM, CO, CO2, and SO2 emissions. Twelve samples were gathered at the outlet forthe NOx analysis.

The CEM data on inlet SO2 emissions averaged 168 parts per million (ppm). However, with theexception of the first run on the inlet, all Method 6 SO2 data indicated 0 ppm. As a result, the inletMethod 6 data were discarded because it was suspected that the SO2 was reacting with lime particles onthe filter at the front of the Method 6 sampling train. No explanation is given as to why this problem didnot occur during the first inlet run. The outlet data for both the Method 6 train and the CEM indicatednegligible SO2 emissions.

The PM, NOx, CO, and CO2 data are rated B. The Method 6 SO2 data are not rated because theresults from only one run were valid. The CEM data for SO2 emissions are rated D because they arebased on a single gas flow rate measurement, and there is no evidence in the report that the instrumentwas certified. The particle size data are rated C because no measurements of mass loading were made atthe scrubber inlet, and only two of the three outlet runs were valid because of impactor overloading.

4.2.1.14 Reference 15. This test report documents measurements of filterable and condensibleinorganic PM, SO2, NOx, CO, and CO2 emissions from a coal-fired rotary kiln and filterable andcondensible inorganic PM emissions from an atmospheric hydrator. The report mentioned that the plantwas switching its fuel from natural gas to coal during the first day of sampling, but did not elaborate onthis change in process. The emissions from the kiln are controlled with a fabric filter. The tests wereperformed in September 1975 and were sponsored by EPA to collect data for setting standards on newand modified sources.

Process rates for the kiln are provided on the basis of lime production, and process rates for thehydrator are provided on the basis of both lime feed and hydrated lime production.

Emissions of PM, SO2, NOx, and CO were measured using Methods 5, 6, 7, and 10, respectively. Sulfur dioxide emissions also were measured by CEM. Carbon dioxide concentrations were measuredusing Orsat. Six SO2 runs and four CO runs were conducted on the fabric filter inlet; six PM, six SO2,and three NOx runs were conducted on the outlet of the fabric filter. Four runs of the kiln PM test wereslightly anisokinetic (111 to 118 percent). The first SO2 sample at the inlet was discarded due to a non-steady-state process at the plant. All of the outlet SO2 samples were below the detection limit. Three PMruns were conducted on the outlet of the wet scrubber controlling emissions from the atmospherichydrator. Two of these runs also were reported as slightly anisokinetic (89 and 119 percent).

Emission factors were developed for emissions of filterable and condensible inorganic PM, SO2,NOx, CO, and CO2 emissions from the kiln and for filterable and condensible inorganic PM emissionsfrom the hydrator.

The PM data for both the kiln and hydrator are rated C because of the number of anisokineticruns. The NOx, CO, CO2, and Method 6 SO2 data are rated B. The methodologies were sound, and nosignificant problems were reported, but the report lacked adequate documentation for a higher rating. The CEM SO2 data are rated D because only an average emission rate based on a single gas flow ratemeasurement is presented, and there is no evidence in the report that the instrument was certified.

4.2.1.15 References 16, 17, 18. These test reports were supplied by the National LimeAssociation as Exhibits 1, 2, and 3, respectively. The purpose of the tests were not specified, althougheach measured filterable and condensible inorganic PM emissions from coal-fired rotary kilns that were

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controlled with fabric filters. In two of the tests (References 16 and 18), new bags had been installed inthe fabric filters prior to testing. The tests were conducted between May and August of 1977. InReference 16, process rates are provided on the basis of both stone feed and lime production. InReferences 17 and 18, process rates were provided on the basis of feed, and production rates wereestimated as half of the feed rate.

Each of the tests were conducted in a similar fashion. Filterable PM emissions were measured ina single fabric filter compartment using Method 5. Thus, emissions from the entire fabric filter wereestimated by multiplying the emission rate for the compartment measured by the number ofcompartments. Two of the fabric filters (References 17 and 18) consisted of six compartments, and oneof the fabric filters comprised 12 compartments. Details on the back-half analysis for condensible PMare not provided in the reports. In the tests documented in References 16 and 17, six PM runs wereconducted, and in the test documented in Reference 18, three runs were conducted.

Carbon dioxide emissions were measured using Orsat. In Reference 16, two CO2 emissionmeasurements are reported, and in References 17 and 18 the average of three CO2 emissionmeasurements are reported.

Emission factors were developed for filterable and condensible inorganic PM emissions and forCO2 emissions from rotary lime kilns. The PM data are rated D because emissions were measured inonly 1 of 6 or 1 of 12 fabric filter compartments, and total emissions were estimated based on theassumption that emissions from all compartments were comparable. The CO2 emission data fromReferences 17 and 18 also are rated C for the same reason. The CO2 emission data from Reference 16were downrated to D because only two CO2 emission measurements are reported.

4.2.1.16 Reference 19. This test report documents measurements of PM emissions from anatmospheric hydrator that is controlled with a medium-energy wet scrubber. The test was performedApril 16 to 18, 1974 and was sponsored by EPA to obtain background data for developing an NSPS forlime manufacturing. Process rates were provided on the basis of both lime feed and hydrated limeproduction.

Method 5 was used to measure PM emissions, and three test runs were conducted. Run 2 of thetest was slightly anisokinetic (115 percent). However, the results from Run 2 are comparable to theresults of the other two runs. For the third run, a larger nozzle size was used to ensure that the run wasisokinetic. Emission factors were developed for filterable and condensible inorganic PM emissions. Carbon dioxide concentrations in the exhaust were negligible.

The emission data are rated B. The methodology was sound, and no major problems werereported. However, because one of the runs was anisokinetic, an A rating was not warranted.

4.2.1.17 Reference 20. This test report documents measurements of PM and NOx emissionsfrom two calcimatic lime kilns (Kiln 1 and Kiln 2) and from a calcimatic lime kiln (Kiln 1) cooler. Thekilns are fired with natural gas. The tests were performed in October 1975 and were sponsored by EPAas part of a data acquisition program. Process rates were provided on the basis of both stone feed andlime production.

The exhaust system for the kilns is designed to direct 95 percent of the exhaust from Cooler 1 tothe exhaust duct serving Kiln 1; the remaining 5 percent of the exhaust from Cooler 1 is ducted to theexhaust duct serving Kiln 2. The exhaust from Kiln 1 was sampled downstream of the junction with the

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cooler exhaust duct. As a result, the measured emissions from Kiln 1 consist of the emissions from thekiln and approximately 95 percent of the cooler emissions. The measured emissions for Kiln 2 consistof the emissions from the kiln and approximately 5 percent of the cooler emissions.

Emissions from the kilns and from the cooler were sampled for uncontrolled filterable andcondensible inorganic PM and CO2 emissions. Method 5 was used to measure PM emissions, and CO2

emissions were measured using Orsat. Two runs were conducted on each of the sources. In addition, theexhaust from Kiln 1 was tested for NOx emissions. Five NOx runs were conducted using Method 7.

Emission factors were developed for filterable and condensible inorganic PM, NOx, and CO2

emissions. In determining the PM and CO2 emission factors for Kiln 1, 95 percent of the emissions fromCooler 1 were subtracted from the measured emission rate for the preheater; in determining the emissionfactors for Kiln 2, 5 percent of the emissions from Cooler 1 were subtracted from the measured emissionrate for the preheater. The emission factor for NOx emissions from Kiln 1 are based on the measuredemissions only because NOx emissions from the cooler were not measured. However, cooler NOx

emissions should have been negligible in comparison to the kiln NOx emission rate.

The production rates for the kilns are comparable--Kiln 1 produces 182 Mg/day (200 tons/day)and Kiln 2 produces 227 Mg/day (250 tons/day). However, based on this emission test, the emission ratefor Kiln 2 is more than an order of magnitude higher than the emission rate for Kiln 1. No explanationfor this disparity is provided in the report.

The PM emission data for the kilns are rated D because only two runs were conducted and theexhaust system configuration precluded isolating kiln emissions from cooler emissions. The NOx datafor the kilns are rated C because only two runs were conducted and there is some uncertainty in themeasured rate due to the contribution of the cooler to the exhaust stream sampled. The kiln CO2

emission data and the cooler PM and CO2 also are rated C because only two runs were conducted.

4.2.1.18 Reference 21. This test report documents measurements of CO2 and SO2 emissionsfrom three coal-fired rotary lime kilns (Kilns 4, 5, and 6). The sulfur contents of the coal during the testranged from 2.4 to 4 percent. The tests were conducted in January 1976 and were sponsored by EPA. The purpose of the tests was to collect data for an NSPS for lime manufacturing. Process rates wereprovided on the basis of feed; production rates were estimated as half of the feed rate.

The exhausts from the three kilns each pass through a settling chamber and into a commonplenum that distributes the gases among the 22 compartments of a fabric filter. Two of the kilns (Kilns 4and 5) were equipped with preheaters. An attempt was made to sample the fabric filter inlets. However,the three fabric filter inlet streams were very difficult to sample because buildup of lime particles in thesampling probe either choked the probe intake or neutralized the SO2. As a result, only the fabric filteroutlet was sampled.

Emissions of SO2 were measured using Method 6, and a total of six runs were conducted. Concentrations of CO2 were measured using Orsat. Nine CO2 measurements were made on the Kiln 4inlet, seven measurements on the Kiln 5 inlet, and eight measurements on the Kiln 6 inlet. Three CO2

measurements were made on the combined fabric filter outlet for the three kilns. Emission factors weredeveloped for SO2 emissions from the combination of all three kilns and for CO2 emissions from each ofthe three kilns.

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The SO2 data are rated C because they are based on an average flow rate measurement, and thedata represent emissions from a combination of kilns, two of which had preheaters and one of which didnot. The CO2 data are rated B. The test methodology was sound, and no problems were reported. However, because production rates were estimated based on feed rates, a higher rating is not warranted.

4.2.1.19 Reference 22. This test report documents measurements of CO, CO2, and SO2

emissions from two coal-fired rotary kilns. Kiln 1 produces dolomitic lime, and Kiln 2 produces dead-burned dolomite. The sulfur content of the coal used during the test ranged from 2.70 to 3.74 percent. Process rates were provided on the basis of feed; production rates were estimated as half of the feed rate. Emissions from the kilns are controlled with venturi scrubbers. The tests were conducted fromDecember 2 through 9, 1975 and were sponsored by EPA. The purpose of the tests was to gatherinformation necessary to set performance standards for lime manufacturing.

The waste gas from each kiln is ducted to a separate cooler, settling chamber, and wet scrubber,and both the inlets and outlets of the scrubbers were sampled. Each sample was analyzed for CO, CO2,and SO2. Methods 1 and 2 were used to determine stack gas velocity. Method 2 was altered to accountfor cyclonic flow of the stack gas. The probe was first angled so that there was no pressure differentialacross the pitot tube. The probe was then rotated 90E and the pressure was measured.

Carbon dioxide concentrations were determined per Method 3 using Orsat. Sulfur dioxideconcentrations were determined per Method 6 with the following modifications: (1) at the outletlocations, no glass wool filter was used in the sampling probe and (2) at the inlet locations a speciallydesigned probe (shielded gas pickup ports) was used to decrease particle entrainment in the sample. Sixuncontrolled SO2 runs were conducted on each kiln, five controlled SO2 runs were conducted on Kiln 1,and six controlled SO2 runs were conducted on Kiln 2. Scrubber inlet flow rates were not measured, sothe uncontrolled SO2 emission rates were determined by estimating inlet flow rates based on the flowrates measured at the scrubber outlets. In addition, the scrubber outlet flow rates for three of the six runson Kiln 2 were estimated based on the three runs for which flow rates were measured.

Carbon monoxide samples were gathered in accordance with Method 10 except that no ascaritescrubber was used to correct for CO2 interference. The authors of this report suspect that the error isapproximately + 10 to 15 ppm. Four CO runs were conducted on the Kiln 1 scrubber inlet and outlet,and two CO runs were conducted on the Kiln 2 scrubber inlet and outlet. The concentrations at the outletwere measured to be higher than the inlet concentrations.

Emission factors were developed for uncontrolled and controlled SO2 emissions from kilnsproducing dolomitic lime and dead-burned dolomite. Emission factors also were developed for COemissions from both kilns. For Kiln 1, the results of all eight runs (four inlet and four outlet) wereaveraged to produce a single CO emission factor. Similarly, for Kiln 2, the results of all four runs (twoinlet and two outlet) were averaged to produce a single CO emission factor. Emission factors for CO2

emissions were developed by the same procedure as the emission factors for CO.

The emission data for uncontrolled SO2 emissions are rated C because they are based onestimated gas flow rates. The emission data for controlled SO2 emissions are rated B. Although themethodology was sound, the report lacked adequate documentation to warrant an A rating. The CO2

emission data also are rated B for the same reason. The CO emission data are rated C because ofsuspected CO2 interference in the sampling and analysis.

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4.2.1.20 Reference 23. This test report documents measurements of filterable PM and CO2

emissions from a coal-fired rotary kiln. Emissions from the kiln are controlled with the combination of amulticlone and a venturi scrubber. The test was conducted in October 1990 to demonstrate compliancewith State regulations. Process rates were provided on the basis of feed; production rates were estimatedas half of the feed rate.

Method 5 was used to measure PM emissions, and CO2 concentrations in the exhaust streamwere measured using Orsat. Three test runs were conducted. Emission factors were developed forcontrolled filterable PM emissions and for CO2 emissions from the kiln.

The emission data are rated B. Although the methodology was sound, the report lacked adequatedocumentation to warrant an A rating.


emissions from a different coal-fired rotary kiln located at the same facility as in Reference 23. Emissions from the kiln are controlled with the combination of a multiclone and a venturi scrubber. Thetest was conducted in October 1991 to demonstrate compliance with State regulations. Process rateswere provided on the basis of feed; production rates were estimated as half of the feed rate.




emissions from a rotary kiln. The kiln was fired with a combination of 30 percent coal and 70 percentpetroleum coke. Emissions from the kiln are controlled with the combination of a settling chamber,multiclone, and venturi scrubber. The test was conducted in October 1986 to demonstrate compliancewith State regulations. Process rates were provided on the basis of feed; production rates were estimatedas half of the feed rate.



4.2.1.23 Reference 26. This test report documents measurements of filterable PM, SO2, NOx,and CO2 emissions from a different coal-fired rotary kiln located at the same facility as in Reference 25. Emissions from the kiln are controlled with the combination of a multiclone and a fabric filter. The testwas conducted in July 1991 to demonstrate compliance with State regulations. Process rates wereprovided on the basis of feed; production rates were estimated as half of the feed rate.

Method 5 was used to measure PM emissions; NOx emissions were quantified using Method 7E;Method 8 was used to measure SO2 emissions; and CO2 concentrations in the exhaust stream were

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measured using Orsat. Three test runs were conducted. Emission factors were developed for controlledfilterable PM, NOx, SO2, and CO2 emissions from the kiln.


4.2.1.24 Reference 27. This test report documents measurements of controlled filterable andcondensible inorganic PM emissions from a gas-fired rotary kiln. The kiln was equipped with a gravelbed filter to control PM emissions. It is unclear from the report if the process rates specified are for feedor production. The test was conducted on September 20, 1972 following the change of filter media in thegravel bed filter.

Two test runs were performed in accordance with EPA Method 5, and no difficulties were noted. The sampling points were located downstream of the gravel bed filter, and filterable and condensibleinorganic PM emissions were measured. Emission factors for filterable and condensible inorganic PMemissions were developed based on the assumption that the process rate provided was for kiln feed,because feed rate is more commonly reported than is production rate.

The emission factors developed in this reference were rated D. Only two test runs wereconducted, process rates were not clearly described, and the test report lacked other documentation towarrant a higher rating.

4.2.1.25 Reference 28. This test report documents measurements of filterable and condensibleinorganic PM, SO2, NOx, trace metals, and CO emissions from a coal-fired rotary lime kiln. Emissionsfrom the kiln are controlled with a fabric filter. The sulfur content of the coal ranged from 0.5 to 1.5percent. Process rates were provided on the basis of feed; production rates were estimated as half of thefeed rate. The test was sponsored by EPA and was conducted in January 1974 to provide information foran NSPS for lime manufacturing.

Method 5 was used to measure PM emissions; Method 6 was used to measure SO2 emissions;NOx emissions were quantified using Method 7; Method 10 was used to measure CO emissions; and CO2

concentrations in the exhaust stream were measured using Orsat. Three test runs were conducted. Inaddition, a trace metal analysis was performed on the PM catches for one run on two separate stacks.

Testing was conducted on the four stacks that serve the fabric filter. Two stacks were tested byan EPA contractor and the other two stacks were tested by the facility. Data for the two stacks tested bythe facility were not available. The total plant emissions were estimated by doubling the emissions fromthe two stacks tested by the EPA contractor because the emission rates from the other stacks wereconsidered to be comparable to the emission rates from the two stacks tested. Emission factors weredeveloped for controlled filterable PM, NOx, SO2, CO, and CO2 emissions from the kiln. The data wereinadequate to develop trace metal emission factors.

The emission data are rated C. The methodology was sound, and no problems were reported. However, emissions from only two of four parallel stacks were measured.

4.2.1.26 Reference 29. This report documents measurements of SO2, NOx, CO, and controlledfilterable, organic, and PM inorganic emissions from a coal-fired rotary kiln with preheater. The test wasconducted in June 1974 and was sponsored by EPA to provide information to be used for developing anNSPS for lime manufacturing. The exhaust gas from the kiln first passes through a multiclone, then is

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cooled with a combination of water spray and tempering air, and then is ducted to a fabric filter. Thefabric filter has 12 compartments and six stacks. Process rates were provided on the basis of feed;production rates were estimated as half of the feed rate. Operation of the kiln and fabric filter wasreported to be normal during the testing.

Particulate matter emissions were measured generally in accordance with Method 5. Twovariations to the standard protocol were reported. One hundred milliliters (ml) of water were added tothe third impinger, and the testing crew used a stationary impinger box connected to the heated filter boxwith teflon tubing. Neither variation was considered to introduce significant error in the data. One PMrun was conducted on each of the six stacks. The back half of the Method 5 sampling train was analyzedfor condensible inorganic PM and condensible organic PM. The data tables in the report indicate that anorganic extract was used to quantify the organic fraction, but no other details are provided.

Sulfur dioxide testing was conducted in accordance with Method 6. One SO2 run was conductedon each of the six stacks. The tests were not run for the complete 4-hour period due to carry-over of thesulfuric acid fraction in the isopropanol impinger. No other problems were reported with the SO2

sampling. Testing for NOx was conducted in accordance with EPA Method 7. Four samples werecollected during each of three PM runs. No difficulties with the NOx testing were reported. Testing forCO was conducted generally in accordance with EPA Method 10. One run was conducted during each ofthree PM runs. Integrated bag samples were collected during the PM testing, but difficulties wereencountered during the testing while passing the sample through the ascarite. This difficulty caused aflow restriction in the inlet tube to the ascarite container. The report does not discuss the effect thisproblem could have had on the results. However, the data showed a wide range in CO concentrations (15to 580 ppm). Emission factors for CO2 were developed using data from the Orsat analysis. These datawere generated during the PM testing.

Emission factors were developed for filterable PM, condensible inorganic PM, condensibleorganic PM, SO2, NOx, and CO2 emissions. The emission data for CO are rated D because of thesampling difficulties and the wide range in the data. All other emission data are rated C. The PM, SO2,and CO2 data constitute a single run on the entire fabric filter. In addition, details on the back-halfanalysis of the PM sampling train are not provided. The NOx data constitute a single run on three of thesix fabric filter stacks.

4.2.1.27 Reference 30. This report documents measurements of uncontrolled and controlledfilterable PM emissions from a rotary lime kiln. The kiln was fired by 50 percent coal and 50 percentnatural gas. The test was conducted in May 1974 to evaluate the efficiency of the horizontal venturiscrubber on the lime kiln. Process rates are provided on the basis of lime production.

The PM sampling and analytical methods are not specified in the report. Three test runs wereconducted upstream and downstream of the scrubber. Data for the first test run were discounted becausethe isokinetic flow rate was unacceptable. Concentrations of CO2 in the exhaust stream were measuredusing Orsat, but only a single reading is reported.

Emission factors were developed for uncontrolled and controlled filterable PM emissions and forCO2 emissions. The PM data are rated D because the test and analytical methods were not specified, andthe report generally was lacking in other details. The CO2 data are unrated because only a singlemeasurement was recorded.

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4.2.1.28 Reference 31. This report documents measurements of controlled filterable andcondensible inorganic PM emissions from a rotary lime kiln. Particulate emissions from the kiln werecontrolled by a venturi scrubber. The test was conducted on September 23, 1975 as a compliance test. The fuel for the kiln was not reported. Process rates were provided on the basis of feed; production rateswere estimated as half of the feed rate.

Three test runs were conducted on the outlet to the venturi scrubber. The tests were conducted inaccordance with EPA Method 5, but it is unclear from the report which portion of the sample catchrepresented filterable PM and which portion represented condensible inorganic PM. In addition, thereport does not describe the method of sample analysis.

Emission factors were developed for controlled filterable and condensible inorganic PMemissions. The emission data are rated D because of the lack of adequate documentation in the report.

4.2.1.29 Reference 50. This report documents measurements of emissions of filterable PM fromsix raw material processing sources and measurements of emissions of filterable PM, SO2, NOx, and COfrom a parallel flow regenerative lime kiln that was fueled with natural gas. The raw material processingsources tested included the following stages of the process: primary crushing, including the scalpingscreen, scalping screen discharges, primary crusher, primary crusher discharges, and ore discharge;primary screening, including the screen feed, screen discharge, and surge bin discharge; two conveyortransfer points on the conveyor from the primary crusher to the primary stockpile; secondary and tertiaryscreening (two points), including the conveyor transfer point for the primary stockpile underflow to thesecondary screen, secondary screen, tertiary screen, and tertiary screen discharge.

Fabric filters are used to control emissions from each of the sources tested, and only controlledemissions were tested. The test was conducted in February 1993 to demonstrate compliance with Stateregulations. Process rates were provided on the basis of feed rate for the raw material processing sourcesand lime production rate for the kiln.

Filterable PM emissions were quantified using Method 5; SO2 emissions were quantified usingMethod 6C; NOx emissions were quantified using Method 7E; and CO emissions were quantified withMethod 10. In all cases, three test runs were conducted.

Emission factors for filterable PM were developed from all seven sources. The emission factorsfor the conveyor transfer points were combined to yield an average filterable PM emission factor becauseboth sources were located on the same conveyor. In addition, the emission factors for bothsecondary/tertiary screening sources were combined because both emission points included acombination of sources associated with both secondary and tertiary screening, and the report did notprovide adequate information for isolating secondary from tertiary screening. Table 4-3 includes onlythe combined data for these four sources.

Emission factors also were developed for emissions of filterable PM, SO2, NOx, and CO from theparallel flow regenerative kiln. All of the emission factors developed from this reference are rated A.

4.2.2 Estimate of Theoretical CO2 Emission Factors for Lime Kilns

Carbon dioxide is emitted from lime manufacturing kilns by two mechanisms: the reduction ofcarbonate (CO3

-2) in the limestone feed material to CO2 and the oxidation of carbon in the fuel to CO2. Assuming complete reduction of CO3

-2, the emission factor for the first reaction in units of kg of CO2 per

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Mg of lime produced is estimated to be 920 kg/Mg (1,830 lb/ton) for dolomitic lime and 785 kg/Mg(1,570 lb/ton) for high-calcium lime.

The CO2 emission factor for the second reaction is a function of the carbon content of the fueland the fuel consumption rate. Based on the test reports reviewed for this report, the consumption ratefor coal, the most commonly used fuel in lime kilns, ranged from 0.18 to 0.35 and averaged 0.27 Mg coalper Mg of lime produced. The carbon content of bituminous coal ranges from 75.5 percent to 90.5percent by weight; the midpoint of this range is 83 percent. Assuming complete oxidation of C to CO2,the emission factor for the second reaction ranges from 498 kg/Mg (997 lb/ton), for 75.5 percent carboncoal utilized at a fuel consumption rate of 0.18 Mg/Mg, to 1,160 kg/Mg (2,320 lb/ton) for 90.5 percentcarbon coal utilized at a consumption rate of 0.35 Mg/Mg. Using the average coal consumption rate of0.27 Mg/Mg and an average carbon content of 83 percent, the average emission factor due to combustionis estimated as 820 kg/Mg (1,640 lb/ton).

Combining the CO2 emission factors for the two reactions yields average CO2 emission factors of1,750 kg/Mg (3,500 lb/ton) for dolomitic lime and 1,600 kg/Mg (3,200 lb/ton) for high-calcium lime. Asthese results indicate, the first of these two reactions accounts for approximately 70 to 85 percent of theCO2 emissions from lime kilns, depending on the carbon content of the fuel, the fuel consumption rate,and the type of lime produced. The calculations and data that form the basis for these CO2 emissionfactor estimates are provided in Appendix A.

4.2.3 Review of XATEF and SPECIATE Data Base Emission Factors

The XATEF data base did not include any emission factors for the lime manufacturing industry. The SPECIATE data base includes emission factors for a number of speciated inorganic and volatilecompounds (VOC's) from limestone loading, crushing, screening, conveying, calcining, cooling,hydrating, and storing. However, the emission factors are all surrogates, which are based on averages forthe mineral products industry as a whole.

4.2.4 Review of Test Data in AP-42 Background File

As stated in Section 4.2 of this report, the majority of documents used to prepare this revision toAP-42 were found in the background file for the section; only five new test reports (References 23 to 26and Reference 50) were reviewed. All of the references were described previously in Section 4.2.1 ofthis report.

The previous version of AP-42 includes emission factors for controlled calcimatic kilns and foruncontrolled vertical kilns. However, data on emissions from these sources could not be located in thebackground file. Apparently, the data on which these emission factors were based were found inReference 5 of the previous version of the section. This reference is identified in the list of references as"Source test data on lime plants, Office of Air Quality Planning and Standards." Because there was noway to corroborate the data, these emission factors from the previous version of Section 11.15 were notretained in the revised section.

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4.2.5 Results of Data Analysis

This section discusses the analysis of the data and describes how the data were used to developaverage emission factors for lime manufacturing. These average emission factors are listed in Table 4-5. As described in Section 4.2, emission factors for kilns, coolers, and hydrators are presented in units ofmass of pollutant emitted per mass of lime produced. Emission factors for mechanical processing, suchas screening, grinding, and materials transfer, are presented in units of mass of pollutant emitted per massof material processed. The following paragraphs describe how the emission data from individual testreports were used to develop the average emission factors for lime manufacturing. Emission factors forrotary kiln emissions are discussed first, followed by emission factors for calcimatic kilns, parallel flowregenerative kilns, hydrators, product coolers, and other material processing sources.

The emission factor ratings assigned to each of the average emission factors developed for limemanufacturing are based on the emission data ratings and the number of tests conducted. Of the 145 datasets from which emission factors were developed, 19 were A-rated, 34 were B-rated, 62 were C-rated,and 30 were D-rated. In general, A- and B-rated data are not supposed to be averaged with C- and D-rated data. However, emission factors based on C-rated data were averaged with A- and B-rated data ifthe number of C-rated tests were relatively large in comparison to the A- and B-rated tests and the datawere consistent between A-, B-, and C-rated tests. D-rated data were used only when no A- or B-rateddata were available.

4.2.5.1 Coal-Fired Rotary Kilns.

Filterable PM. Emission factors for uncontrolled filterable PM emissions from coal-fired rotarykilns were developed from two A-rated tests. The results of these two tests, 170 and 190 kg/Mg (330 and370 lb/ton), were averaged to produce an average emission factor of 180 kg/Mg (350 lb/ton) foruncontrolled filterable PM emissions. This emission factor is rated D.

Emission factors for filterable PM emissions from large-diameter cyclone-controlled rotary kilnsare available for one A-rated test and one C-rated emission test. A-rated data generally are not averagedwith C-rated data. In addition, the A-rated test consisted of 15 runs, whereas the C-rated test consisted ofonly 2 test runs. Therefore, the C-rated data were discarded, and only the A-rated data were used todevelop the emission factor for filterable PM emissions controlled with a large-diameter cyclone. Thisemission factor is rated D.

Emission factors for filterable PM emissions from fabric filter-controlled rotary kilns areavailable for one A-rated test, one B-rated emission test, two C-rated tests, and four D-rated tests. Theemission factors developed from D-rated data averaged 0.61 kg/Mg (1.2 lb/ton), and the emission factorsdeveloped from the remaining data averaged 0.14 kg/Mg (0.28 lb/ton). The D-rated data were discarded,and the A-, B-, and C-rated data were used to develop the average emission factor for filterable PMemissions with fabric filter control. This emission factor is based on a total of five tests and is rated D.

For filterable PM emissions from ESP-controlled rotary kilns, data were available only from asingle A-rated test. This emission factor is rated D.

Emission factors for filterable PM emissions from venturi scrubber-controlled rotary kilns weredeveloped from three B-rated emission tests, two C-rated tests, and one D-rated test. The emissionfactors developed from B-rated data average 0.72 kg/Mg (1.4 lb/ton), and the emission factors developedfrom C-rated data average 3.1 kg/Mg (6.1 lb/ton). Only the B-rated data were used to determine the

49

average emission factor for filterable PM emissions from venturi scrubber controlled rotary kilns. Thisemission factor is based on three emission tests and is rated D.

Filterable PM-10. Particle size distribution data were available for uncontrolled rotary kilns,ESP-controlled rotary kilns, and fabric filter-controlled rotary kilns. The size distributions aresummarized in Table 4-4. Emission factors for PM-10 emissions from coal-fired rotary kilns weredeveloped by multiplying the cumulative percent below 10F by the average filterable PM emissionfactors developed for coal-fired rotary kilns. The PM-10 emission factors are rated D. These emissionfactors were developed from a combination of A- and C-rated particle size data and D-rated filterable PMemission factors.

Condensible inorganic PM. For condensible inorganic PM emissions from rotary kilns, datafrom two emission tests were available: one test on an uncontrolled kiln, and one test on a large-diametercyclone-controlled kiln. The data from both tests were rated C. Because cyclones are expected to havenegligible effects on condensible inorganic PM emissions, emission factors developed from the two testswere averaged. The resulting average emission factor is rated E.

Emission factors for condensible inorganic PM emissions from fabric filter-controlled rotarykilns were developed from two C-rated tests and four D-rated tests. The emission factor developed fromC-rated data averaged 0.13 kg/Mg (0.25 lb/ton), and the emission factor from D-rated data averaged 0.22kg/Mg (0.45 lb/ton). The average emission factor for condensible inorganic PM emissions from fabricfilter-controlled rotary kilns was determined by averaging the results from all six tests. This emissionfactor is rated E.

Emission factors for condensible inorganic PM emissions from venturi scrubber-controlled rotarykilns were developed from one B-rated emission test, two C-rated tests, and one D-rated test. The B-rated test (0.12 kg/Mg [0.24 lb/ton]) and one of the C-rated tests (0.33 kg/Mg [0.65 lb/ton]) wereconducted on the same rotary kiln, and the results from these two tests were first averaged to determinean average emission factor from that specific kiln. This emission factor was then averaged with theemission factor from the other C-rated test in order to determine the average emission factor

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TABLE 4-5. SUMMARY OF AVERAGE EMISSION FACTORS FOR LIMEMANUFACTURINGa

SourceType ofcontrol Pollutant

No. oftests

Emission factor,

Rating Referenceskg/Mg lb/ton

Rotary kiln (coal-fired) None Filterable PM 2 180 350 D 6, 7

Rotary kiln (coal-fired) None Filterable PM-10 b 22 42 D 1, 6, 7

Rotary kiln (coal-fired) Large diam.cyclone

Filterable PM 1 60 120 D 7

Rotary kiln (coal-fired) Fabric filter Filterable PM 4 0.14 0.28 D 7, 15, 26, 28

Rotary kiln (coal-fired) Fabric filter Filterable PM-10 b 0.077 0.15 D 1, 7, 15, 26,28

Rotary kiln (coal-fired) ESP Filterable PM 1 4.3 8.5 D 7

Rotary kiln (coal-fired) ESP Filterable PM-10 b 2.2 4.3 D 1, 7

Rotary kiln (coal-fired) Venturiscrubber

Filterable PM 3 0.72 1.4 D 5, 23, 24

Rotary kiln (coal-fired) None Condensibleinorganic PM

2 0.67 1.3 E 6,8

Rotary kiln (coal-fired) Fabric filter Condensibleinorganic PM

6 0.19 0.38 E 3, 15, 16, 17,18, 28


Condensibleinorganic PM

3 0.14 0.28 D 5, 10, 11

Rotary kiln (coal-fired) None Condensibleorganic PM

1 0.51 1.0 E 6

Rotary kiln (coal-fired) None SO2 2 2.7 5.4 D 6, 15

Rotary kiln (coal-fired) Fabric filter SO2 3 0.83 0.17 D 15, 26, 28

Rotary kiln (coal-fired) Wet scrubber SO2 2 0.15 0.3 D 22

Rotary kiln (coal-fired) None NOx 5 1.6 3.1 C 6, 8, 15, 26,28

Rotary kiln (coal-fired) None CO 3 0.74 1.5 D 15, 22

Rotary kiln (coal-fired) None CO2 9 1,600 3,200 C 5, 6, 21, 22,23, 24, 26


SO3 1 0.11 0.21 E 10

Rotary kiln (gas-fired) ESP Filterable PM 1 0.086 0.17 E 9

Rotary kiln (gas-fired) Gravel bed Filterable PM 2 0.51 0.99 E 12, 27

Rotary kiln (gas-fired) ESP Condensibleinorganic PM

1 0.11 0.22 E 9

Rotary kiln (gas-fired) Gravel bedfilter


1 0.24 0.48 E 12, 27

Rotary kiln (gas-fired) None NOx 1 1.7 3.5 E 9

Rotary kiln (gas-fired) None CO 1 1.1 2.2 E 9

Rotary kiln(coal/gas-fired)

None Filterable PM 1 40 80 E 14



No. oftests

Emission factor,


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Venturiscrubber

Filterable PM 1 0.44 0.87 D 14


Venturiscrubber


1 0.041 0.082 D 14


Venturiscrubber

NOx 1 1.4 2.7 D 14


Venturiscrubber

CO 1 0.41 0.83 D 14


Venturiscrubber

CO2 1 1,600 3,200 D 14

Rotary kiln(coal/coke-fired)

Venturiscrubber



Venturiscrubber

CO2 1 1,500 3,000 D 25

Rotary preheater kiln(coal-fired)

Multiclone Filterable PM 1 42 84 E 8


Gravel bedfilter

Filterable PM 1 0.59 1.2 E 13


Multiclone/water spray/fabric filter

PM, filterable 1 0.56 1.1 E 29



PM, condensibleinorganic

1 0.57 1.1 E 29



PM, condensibleorganic

1 0.076 0.15 E 29


Multiclone Condensibleinorganic PM

1 0.040 0.081 E 8


Dry PMcontrols

SO2 2 1.1 2.3 E 13, 21



SO2 1 3.2 6.4 E 29


None CO 1 3.2 6.3 E 29


None CO2 3 1,200 2,400 D 21





No. oftests

Emission factor,


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None Condensibleinorganic PM

1 0.14 0.27 E 20


None NOx 1 0.076 0.15 D 20


None CO2 1 1,300 2,700 E 20

Parallel flow regenerativekiln (gas-fired)

Fabric filter PM, filterable 1 0.026 0.051 D 50


Fabric filter SO2 1 0.00060 0.0012 D 50


None NOx 1 0.12 0.24 D 50


None CO 1 0.23 0.45 D 50

Atmospheric hydrator Wet scrubber Filterable PM 1 0.033 0.067 D 19

Atmospheric hydrator Wet scrubber Condensibleinorganic PM

1 0.0067 0.013 D 19

Cooler None Filterable PM 1 3.4 6.8 E 20

Cooler None Condensibleinorganic PM

1 0.011 0.023 E 20

Cooler None CO2 1 3.9 7.8 E 20

Primary crushingc None Filterable PM 1 0.0083 0.017 E 2

Scalping screen andhammermillc

None Filterable PM 1 0.31 0.62 E 2

Primary crushingd Fabric filter PM, filterable 1 0.00021 0.00043 D 50

Primary screeninge Fabric filter PM, filterable 1 0.00030 0.00061 D 50

Crushed materialconveyor transferf

Fabric filter PM, filterable 1 4.4x10-5 8.8x10-5 D 50

Secondary and tertiaryscreeningg

Fabric filter PM, filterable 1 6.5x10-5 0.00013 D 50

Product transfer andconveyingc


Product loading(enclosed truck)c

None Filterable PM 1 0.31 0.61 D 7

Product loading (opentruck)c


aEmission factors in units of kg/Mg (lb/ton) of lime produced except where indicated.


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bBased on average particle size distribution presented in Table 4-4.cEmission factors in units of kg/Mg (lb/ton) of stone or product processed.dEmission factors in units of kg/Mg (lb/ton) of material processed. Includes scalping screen, scalping screendischarges, primary crusher, primary crusher discharges, and ore discharge.

eEmission factors in units of kg/Mg (lb/ton) of material processed. Includes primary screening, including the screenfeed, screen discharge, and surge bin discharge.

fEmission factors in units of kg/Mg (lb/ton) of material processed. Based on average of three runs each ofemissions from two conveyor transfer points on the conveyor from the primary crusher to the primary stockpile.

gEmission factors in units of kg/Mg (lb/ton) of material processed. Based on sum of emissions from two emissionpoints that include conveyor transfer point for the primary stockpile underflow to the secondary screen, secondaryscreen, tertiary screen, and tertiary screen discharge.

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for condensible inorganic PM emissions from venturi scrubber-controlled rotary kilns. This emissionfactor is rated D.

Condensible organic PM. For condensible organic PM emissions from rotary kilns, data fromone emission test were available on an uncontrolled kiln. The test is rated C, and an E-rated emissionfactor was developed from the data set for AP-42 Section 11.15.

Filterable and condensible inorganic PM. Reference 5 documents a Method 5 emission test forwhich the filter was placed after the impingers. Because of this modification to the sampling train, onlycombined uncontrolled filterable and condensible inorganic PM were reported. Because separatefilterable PM and condensible inorganic PM data were presented in several other test reports reviewed,the emission factor developed from these C-rated data were not incorporated in AP-42 Section 11.15. Itshould be noted that the emission factor developed from these Reference 5 data is approximately 33percent less than the uncontrolled filterable PM emission factor developed from other test data.

Sulfur dioxide. For SO2 emissions from coal-fired rotary kilns, emission factors were developedfrom 13 tests. Three tests (rated A, B, and D) were conducted on uncontrolled kilns; two tests (both ratedC) were conducted on kilns with only settling chambers as controls; four tests (two B-rated, one C-rated,and one D-rated) were conducted on fabric filter-controlled kilns; and four tests (two B-rated, one C-rated, and one D-rated) were conducted on kilns controlled with wet scrubbers.

Because settling chambers were assumed to have negligible effects on SO2 emissions, the testresults from the settling chamber-controlled kilns were treated as uncontrolled emissions. The data fromboth of these tests (5.8 and 5.9 kg/Mg [12 and 12 lb/ton]) were rated C. Because A- and B-rated datawere available, the C-rated data were not used in determining an average emission factor for uncontrolledSO2 emissions from rotary kilns. The D-rated data also were discarded. The average emission factordeveloped from the A- and B-rated data is rated D.

Emission factors for SO2 emissions from fabric filter-controlled rotary kilns were developed fromtwo B-rated tests, one C-rated test, and one D-rated test. Fabric filters generally achieve only incidentalcontrol of SO2 emissions. However, the data indicate a significant difference between uncontrolled andfabric filter-controlled SO2 emissions. Therefore, a separate average emission factor was developed forfabric filter-controlled SO2 emissions. The emission factors developed from the B-rated tests averaged1.2 kg/Mg (2.3 lb/ton), the emission factor developed from the C-rated test was 0.18 kg/Mg (0.37 lb/ton),and the emission factor from the D-rated test was calculated as 5.3 kg/Mg (11 lb/ton). The B-rated andC-rated test data were combined to develop an average emission factor for SO2 emissions from fabricfilter-controlled rotary kilns. This emission factor is rated D.

Emission factors for SO2 emissions from wet scrubber-controlled rotary kilns were developedfrom two B-rated tests, one C-rated test, and one D-rated test. The C-rated and one of the B-rated testswere conducted on the same kiln. However, the B-rated test was conducted one year later than the C-rated test, and the B-rated data are an order of magnitude lower than the C-rated data. It is unknown ifthe difference in the results of the two tests was due to a process change. Therefore, the B- and C-rateddata for this kiln were not combined. The D-rated and the other B-rated test also were conducted on thesame kiln. Only the B-rated test data were used to develop an average emission factor for SO2 emissionsfrom wet scrubber-controlled rotary kilns.

Nitrogen oxides. For NOx emissions from coal-fired rotary kilns, emission factors weredeveloped from five emission tests. Two tests (both rated A) were conducted on uncontrolled kilns, and

55

three tests (two rated B and one rated C) were conducted on fabric filter-controlled kilns. Because fabricfilters have a negligible effect on NOx emissions, all five tests were treated as uncontrolled emissionmeasurements. The emission factors from both the combined A- and B-rated data and the C-rated dataaveraged 1.6 kg/Mg (3.0 lb/ton). Because the five tests showed consistent results, the data from all fivetests were used to develop an average emission factor for NOx emissions from coal-fired rotary kilns. Because this emission factor is based on five emission tests and the data are relatively consistent, theNOx emission factor is rated C.

Carbon monoxide. For CO emissions from coal-fired rotary kilns, emission factors weredeveloped from five emission tests. One test was conducted on an uncontrolled kiln, two tests wereconducted on settling chamber-controlled kilns, and two tests were conducted on fabric filter-controlledkilns. Fabric filters and settling chambers generally have negligible effects on CO emissions. Therefore,the results from the five tests were treated as measurements of uncontrolled emissions.

One of the tests was rated B, two of the tests were rated C, and two of the tests were rated D. The D-rated data were discarded. The emission factors developed from the C-rated data ranged from0.45 to 1.4 kg/Mg (0.90 to 2.7 lb/ton). The emission factor developed from the B-rated test wasdetermined to be 0.38 kg/Mg (0.76 lb//ton). Because there was only a single B-rated test and two C-ratedtests, the results from all three B- and C-rated tests were combined to develop an average emission factorfor CO emissions from coal-fired rotary kilns. The average emission factor was determined to be 0.74kg/Mg (1.5 lb/ton). This emission factor is rated D.

Carbon dioxide. For CO2 emissions from coal-fired rotary kilns, emission factors weredeveloped from 17 emission tests. Three tests were conducted on uncontrolled kilns, 5 tests wereconducted on kilns controlled with wet scrubbers, and the other 9 tests were conducted on kilns with PMcontrols (settling chambers or fabric filters), which are expected to have negligible effects on CO2

emissions. Although wet scrubbers generally achieve some level of CO2 control, the emission factorsdeveloped from the wet scrubber-controlled kilns do not indicate a reduction in emissions over theuncontrolled tests. Therefore, the results of all 17 tests were treated as measurements of uncontrolledCO2 emissions.

Of the 17 CO2 emission tests, 1 of the tests was rated A, 8 of the tests were rated B, 6 of the testswere rated C, and 2 of the tests were rated D. Because of the relatively large number of A- and B-ratedtests, the C- and D-rated data were discarded. The emission factors developed from the A- and B-ratedtests ranged from 940 to 2,500 kg/Mg (1,900 to 4,900 lb/ton) and averaged 1,600 kg/Mg (3,200 lb/ton). This emission factor is rated C. In comparison to the theoretical average emission factor for CO2

emissions (1,100 kg/Mg [2,200 lb/ton]) discussed in Section 4.2.2, the magnitude of this averageemission factor appears to be reasonable.

Sulfur trioxide. One of the test reports reviewed included C-rated data on SO3 emissions from aventuri scrubber-controlled rotary kiln. The emission factor for SO3 emissions from coal-fired rotarykilns developed from this report is rated E.

4.2.5.2 Gas-Fired Rotary Kilns.

Filterable PM. Emission factors for filterable PM emissions from gas-fired rotary kilns weredeveloped from three emission tests. One of the tests was conducted on an ESP-controlled rotary kiln. The data from this test were rated C, and an E-rated emission factor was developed from the data. Theother two tests were conducted on rotary kilns controlled with gravel bed filters. The data from one of

56

these tests were rated C and the data from the other test were rated D. The results of these two tests, 0.44and 0.57 kg/Mg (0.87 and 1.1 lb/ton), were combined to develop an average emission factor for filterablePM emissions from a gravel bed filter-controlled gas-fired rotary kiln. This emission factor also is ratedE.

Condensible inorganic PM. Emission factors for condensible inorganic PM emissions from gas-fired rotary kilns also were developed for one ESP-controlled rotary kiln and for two rotary kilnscontrolled with gravel bed filters. The data from the ESP-controlled kiln test were rated C, and anE-rated emission factor was developed from the data. The data from the gravel bed filter-controlled kilntests were rated D. The results of these two tests, 0.022 and 0.46 kg/Mg (0.045 and 0.91 lb/ton), werecombined to develop an average emission factor for condensible inorganic PM emissions from a gravelbed filter-controlled gas-fired rotary kiln. This emission factor also is rated E.

Nitrogen oxides. For NOx emissions from gas-fired rotary kilns, an emission factor wasdeveloped from a single C-rated test conducted on an ESP-controlled kiln. Because ESP's havenegligible effects on NOx emissions, the data were treated as measurements of uncontrolled emissions. The emission factor developed from this test is rated E.

Carbon monoxide. For CO emissions from gas-fired rotary kilns, an emission factor wasdeveloped from a single C-rated test conducted on an ESP-controlled kiln. Because ESP's havenegligible effects on CO emissions, the data were treated as measurements of uncontrolled emissions. The emission factor developed from this test is rated E.

4.2.5.3 Coal- and Gas-Fired Rotary Kilns. Two of the test reports reviewed documented tests onrotary kilns that were fired with a combination of gas and coal. Reference 14 documents measurementsof emissions from a kiln that was fired with 60 percent coal and 40 percent gas (heat value basis), andReference 30 documents emission measurements for a kiln fired with 50 percent coal and 50 percent gas. The emission factors developed from these tests are discussed in the following paragraphs.

Filterable PM. Data were available on one D-rated test of uncontrolled filterable PM emissionsfrom a coal- and gas-fired rotary kiln. The emission factor developed from these data is rated E. Forventuri scrubber-controlled emissions from coal- and gas-fired rotary kilns, two tests were reviewed. Thedata from one of the tests were rated B, and the data from the second test were rated D. The D-rated datawere discarded, and a D-rated emission factor was developed from the B-rated test.

Condensible inorganic PM. For condensible inorganic PM emissions from coal- and gas-firedrotary kilns, an emission factor was developed from a single B-rated test conducted on a venturiscrubber-controlled kiln. This emission factor is rated D.

Nitrogen oxides. For NOx emissions from coal- and gas-fired rotary kilns, an emission factorwas developed from a single B-rated test conducted on a venturi scrubber-controlled kiln. The emissionfactor developed from this test is rated D.

Carbon monoxide. For CO emissions from coal- and gas-fired rotary kilns, an emission factorwas developed from a single B-rated test conducted on a venturi scrubber-controlled kiln. The emissionfactor developed from this test is rated D.

Carbon dioxide. Data were available on one D-rated test and one B-rated test of CO2 emissionsfrom coal- and gas-fired rotary kilns. The D-rated data were discarded. The B-rated test was conducted

57

on a venturi scrubber-controlled kiln. The emission factor developed from this test is rated D. Incomparison to the theoretical average emission factor for CO2 emissions (1,100 kg/Mg [2,200 lb/ton])discussed in Section 4.2.2, the magnitude of this average emission factor appears to be reasonable.

4.2.5.4 Coal- and Coke-Fired Rotary Kilns. One of the test reports reviewed (Reference 25)documented tests on a rotary kiln that was fired with a combination of coke (70 percent) and coal(30 percent). The report includes B-rated data on filterable PM and CO2 emissions from a kiln controlledwith a venturi scrubber. D-rated emission factors were developed for emissions of each of thesepollutants from kilns fired with a combination of coke and coal.

4.2.5.5 Coal-Fired Rotary Kilns with Preheaters. Four of the test reports reviewed documentedtests on coal-fired rotary kilns equipped with preheaters. Reference 8 includes data on filterable andcondensible PM, NOx, and CO2 emissions; Reference 13 includes data on filterable PM, SO2, and CO2

emissions; Reference 21 documents emissions of SO2 and CO2; and Reference 29 documents emissionsof filterable PM, condensible inorganic PM, condensible organic PM, SO2, NOx, CO, and CO2.

Particulate matter. Emission factors for multiclone-controlled filterable PM emissions, gravelbed filter-controlled filterable PM emissions, and multiclone-controlled condensible inorganic PMemissions were each developed from single C-rated tests. In addition, emission factors for filterable PM,condensible organic PM, and condensible inorganic PM from rotary preheater kilns controlled with acombination of multiclone, water spray, and fabric filter were developed from C-rated data. Theseemission factors are rated E.

Sulfur dioxide. Three of the reports documented emissions of SO2 from rotary preheater kilns. In one test, emissions were controlled with a gravel bed filter, and in another test, emissions werecontrolled with a fabric filter. Both of these types of control devices are expected to have a minor butsimilar effect on SO2 emissions. Therefore, the data were treated as SO2 emissions from kilns controlledwith generic dry PM control devices. Both sets of data were rated C, and emission factors developedfrom both (0.33 and 1.9 kg/Mg [0.65 and 3.9 lb/ton]) were combined for an average emission factor of1.1 kg/Mg (2.3 lb/ton). In the third test, emissions were controlled with a combination of multiclone,water spray, and fabric filter. The data from this C-rated test was used to develop an E-rated emissionfactor.

Nitrogen oxides. For NOx emissions from coal-fired rotary preheater kilns, an emission factorwas developed from a single A-rated test conducted on an uncontrolled kiln. The emission factordeveloped from this test is rated D. Data also were available from a C-rated test on a rotary preheaterkiln controlled with a combination multiclone, water spray, and fabric filter. Although these controls areexpected to have a negligible effect on NOx emissions, these data were not combined with the A-rateddata because of their C rating.

Carbon monoxide. Data were available for CO emissions from one test on a rotary preheaterkiln. Kiln emissions were controlled with a combination multiclone, water spray, and fabric filter, whichare expected to have negligible effects on CO emissions. The data were rated D and were used todevelop an E-rated emission factor for uncontrolled CO emissions.

Carbon dioxide. Data were available for three B-rated tests and three C-rated tests of CO2

emissions from coal-fired rotary preheater kilns. One of the kilns was uncontrolled and for the other fivetests kiln emissions were controlled with gravel bed filters, settling chambers, or fabric filters. Becausethese control devices generally have negligible effects on CO2 emissions, the data were treated as

58

measurements of uncontrolled emissions. The emission factors developed from the C-rated dataaveraged 1,900 kg/Mg (3,800 lb/ton), and the B-rated data averaged 1,200 kg/Mg (2,400 lb/ton). The C-rated data were discarded, and the B-rated data were used to develop an average emission factor for CO2

emissions from rotary preheater kilns. This emission factor is rated D. In comparison to the theoreticalaverage emission factor for CO2 emissions (1,100 kg/Mg [2,200 lb/ton]) discussed in Section 4.2.2, themagnitude of this average emission factor appears to be reasonable.

4.2.5.6 Gas-Fired Calcimatic Kilns. One of the test reports reviewed (Reference 20)documented emissions from two gas-fired calcimatic lime kilns. Emission factors were developed foruncontrolled filterable PM, condensible inorganic PM, NOx, and CO2 emissions. The NOx data wererated A and were used to develop a D-rated emission factor for NOx emissions from gas-fired calcimatickilns. All other data from Reference 20 were rated C or D and were used to develop E-rated emissionfactors for gas-fired calcimatic kilns.

4.2.5.7 Gas-Fired Parallel Flow Regenerative Kilns. One of the test reports reviewed (Reference50) documented emissions from a gas-fired parallel flow regenerative kiln. Emission factors weredeveloped for emissions of filterable PM, SO2, NOx, and CO. The data were rated A, and the emissionfactors developed from the data are rated D.

4.2.5.8 Atmospheric Hydrators. Two of the test reports reviewed documented filterable andcondensible inorganic PM emissions from atmospheric lime hydrators controlled with wet scrubbers. Reference 15 includes C-rated data, and Reference 19 includes B-rated data. The C-rated data werediscarded, and D-rated emission factors were developed from the B-rated data for filterable PM andcondensible inorganic PM emissions from lime hydrators.

4.2.5.9 Product Coolers. One of the test reports reviewed documented emissions of uncontrolledfilterable PM, condensible inorganic PM, and CO2 emissions from product coolers. All three data setswere rated C and were used to develop E-rated emission factors for cooler emissions.

4.2.5.10 Raw Material and Finishing Product Processing and Handling. Three of the documentsreviewed documented PM emissions from various raw material and finished product processing andhandling operations. Reference 2 includes C- and D-rated data on emissions from single sources(primary crushers and final sizing screens) and combinations of sources (primary crushers, scalpingscreens, and hammermills). The emissions from the final sizing screens and the combination primarycrusher, scalping screens, and hammermill were controlled with fabric filters. Although condensible PMemissions were quantified, these data were disqualified because condensible emissions from thesesources are considered negligible. Reference 50 includes A-rated data on fabric filter-controlledemissions from primary crushing, primary screening, crushed material conveyor transfer, and secondaryand tertiary screening. Because the data from Reference 50 are of much higher quality, the controlledemission data from Reference 2 were discarded, and the following emission factors were developed forAP-42 Section 11.15: uncontrolled filterable PM for primary crushing; uncontrolled filterable PM forscalping screen and hammermill; and fabric filter-controlled filterable PM for primary crushing, primaryscreening, crushed material conveyor transfer, and secondary and tertiary screening. The uncontrolledemission factors are rated E and the controlled emission factors are rated D.

Reference 7 includes data on filterable PM emissions from material transfer and truck loadingoperations. The material transfer data were rated C and were used to develop an E-rated emission factor. The truck loading emission data include measurements of filterable PM emissions from enclosed trucks

59

(A-rated data) and from open trucks (B-rated data). These data were used to develop D-rated emissionfactors.


1. J. S. Kinsey, Lime And Cement Industry--Source Category Report, Volume I: Lime Industry,EPA-600/7-86-031, U. S. Environmental Protection Agency, Cincinnati, OH, September 1986.

2. Air Pollution Emission Test, J. M. Brenner Company, Lancaster, PA, EPA Project No. 75-STN-7,U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards, ResearchTriangle Park, NC, November 1974.

3. D. Crowell et al., Test Conducted at Marblehead Lime Company, Bellefonte, PA, Report on theParticulate Emissions from a Lime Kiln Baghouse, Marblehead, Lime Company, Chicago, IL. July1975.

4. Wesley D. Snowden, U.S. Lime, Henderson, NV, Valentine, Fisher, & Tomlinson ConsultingEngineers, Seattle, WA, December 1974.

5. Stack Sampling Report of Official Air Pollution Emission Tests Conducted on Kiln No. 1 atJ. E. Baker Company, Millersville, OH, Princeton Chemical Research, Inc., Princeton, NJ, March1975.

6. W. R. Feairheller, and T. L. Peltier, Air Pollution Emission Test, Virginia Lime Company,Ripplemead, VA, EPA Contract No. 68-02-1404, Task 11 (EPA, Office of Air Quality Planning andStandards), Monsanto Research Corporation, Dayton, OH, May 1975.

7. G. T. Cobb et al., Characterization of Inhalable Particulate Matter Emissions from a Lime Plant,Vol. I EPA-600/X-85-342a, Midwest Research Institute, Kansas City, MO, May 1983.

8. W. R. Feairheller et al., Source Test of a Lime Plant, Standard Lime Company, Woodville, OH, EPAContract No. 68-02-1404, Task 12, (EPA, Office of Air Quality Planning and Standards), MonsantoResearch Corporation, Dayton, OH, December 1975.

9. Air Pollution Emission Test, Dow Chemical, Freeport, TX, Project Report No. 74-LIM-6,U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards, ResearchTriangle Park, NC, May 1974.

10. J. B. Schoch, Exhaust Gas Emission Study, J. E. Baker Company, Millersville, OH, George D.Clayton and Associates, Southfield, MI, June 1974.

11. Stack Sampling Report of Official Air Pollution Emission Tests Conducted on Kiln No. 2 Scrubber atJ. E. Baker Company, Millersville, OH, Princeton Chemical Research, Inc., Princeton, NJ, May1975.

12. R. L. Maurice and P. F. Allard, Stack Emissions on No. 5 Kiln, Paul Lime Plant, Inc., EngineersTesting Laboratories, Inc., Phoenix, AZ, June 1973.

60

13. R. L. Maurice, and P. F. Allard, Stack Emissions Analysis, U.S. Lime Plant, Nelson, AZ, EngineersTesting Laboratories, Inc., Phoenix, AZ, May 1975.

14. T. L. Peltier, Air Pollution Emission Test, Allied Products Company, Montevallo, AL, EPA ContractNo. 68-02-1404, Task 20, (EPA, Office of Air Quality Planning and Standards), Monsanto ResearchCorporation, Dayton, OH, September 1975.

15. T. L. Peltier, Air Pollution Emission Test, Martin-Marietta Corporation, Calera, AL, (Draft), EMBProject No. 76-LIM-9, U. S. Environmental Protection Agency, Office of Air Quality Planning andStandards, Research Triangle Park, NC, September 1975.

16. Report on the Particulate Emissions from a Lime Kiln Baghouse (Exhibit 1 supplied by the NationalLime Association), August 1977.

17. Report on the Particulate Emissions from a Lime Kiln Baghouse (Exhibit 2 supplied by the NationalLime Association), May 1977.


19. Air Pollution Emission Test, U.S. Lime Division, Flintkote Company, City of Industry, CA, ReportNo. 74-LIM-5, U. S. Environmental Protection Agency, Office of Air Quality Planning andStandards, Research Triangle Park, NC. October 1974.

20. T. L. Peltier and H. D. Toy, Particulate and Nitrogen Oxide Emission Measurements from LimeKilns, EPA Contract No. 68-02-1404, Task No. 17 (EPA, National Air Data Branch, ResearchTriangle Park, NC), Monsanto Research Corporation, Dayton, OH, October 1975.

21. Air Pollution Emission Test, Kilns 4, 5, and 6, Martin-Marietta Chemical Corporation, Woodville,OH, EMB Report No. 76-LIM-12, U. S. Environmental Protection Agency, Office of Air QualityPlanning and Standards, Research Triangle Park, NC, August 1976.

22. Air Pollution Emission Test, Kilns 1 and 2, J. E. Baker Company, Millersville, OH, EMB ProjectNo. 76-LIM-11, U. S. Environmental Protection Agency, Office of Air Quality Planning andStandards, Research Triangle Park, NC, August 1976.

23. Particulate Emission Tests Conducted on the Unit #2 Lime Kiln in Alabaster, Alabama, for AlliedProducts Corporation, Guardian Systems, Inc., Leeds, AL, October 1990.

24. Particulate Emission Tests Conducted on #1 Lime Kiln in Alabaster, Alabama, for Allied ProductsCorporation, Guardian Systems, Inc., Leeds, AL, October 1991.

25. Mass Emission Tests Conducted on the #2 Rotary Lime Kiln in Saginaw, Alabama, for SI LimeCompany, Guardian Systems, Inc., Leeds, AL, October 1986.

26. Flue Gas Characterization Studies Conducted on the #4 Lime Kiln in Saginaw, Alabama, for DravoLime Company, Guardian Systems, Inc., Leeds, AL, July 1991.

61

27. R. D. Rovang, Trip Report, Paul Lime Company, Douglas, AZ, U. S. Environmental ProtectionAgency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, January 1973.

28. T. E. Eggleston, Air Pollution Emission Test, Bethlehem Mines Corporation Annville, PA, EMB TestNo. 74-LIM-1, U. S. Environmental Protection Agency, Office of Air Quality Planning andStandards, Research Triangle Park, NC, August 1974.

29. Air Pollution Emission Test, Marblehead Lime Company, Gary, Indiana, Report No. 74-LIM-7,U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards, ResearchTriangle Park, NC, 1974.

30. Particulate Emission Test Efficiency Evaluation at Allied Products Corporation Alabaster LimeDivision, Alabama Air Pollution Control Commission, Montgomery, AL, May 1974.

31. Stack Sampling Report of Official Air Pollution Emission Test Conducted on Kiln No. 2 Scrubber atJ.E. Baker Company, Millersville, Ohio, Princeton Chemical Research, Inc., Princeton, NJ, October1975.

32. Air Pollution Test of Woodville Lime and Chemical Company, EPA Report No. 74-LIM-3B, U. S.Environmental Protection Agency, Research Triangle Park, NC, September 1974.

33. Emission Testing Report of Woodville Lime and Chemical Company, EPA Contract No. 68-02-0237,PEDCO Environmental, Cincinnati, OH, July 1974.

34. Particulate, Sulfur Dioxide, and Nitrogen Oxides Emission Measurements from Lime Kilns, EPAContract No. 68-02-1404, Monsanto Research Corporation, Dayton, OH, August 1974.

35. Particulate Emission Test Efficiency Evaluation to Allied Products Corporation, Alabama AirPollution Control Commission, Montgomery, AL, May 1974.

36. Report on the Emissions to the Atmosphere from a Lime Kiln Baghouse at Marblehead LimeCompany, City of Chicago Department of Environmental Control, Chicago, IL, July 1972.

37. Stack Sampling at Round Rock Lime, Round Rock, Texas, Texas Air Control Board, Austin, TX,April 1974.

38. Stack Sampling at Round Rock Lime, Round Rock, Texas, Texas Air Control Board, Austin, TX,November 1974.

39. Stack Sampling at Round Rock Lime, Blum, Texas, Texas Air Control Board, Austin, TX,April 1974.

40. Stack Sampling at Round Rock Lime, Blum, Texas, Texas Air Control Board, Austin, TX,August 1974.

41. Stack Sampling Report at Texas Lime, Cleburne, Texas, Texas State Department of Health, Austin,TX, August 1972.

62

42. Stack Sampling Report at United States Gypsum, Texas State Department of Health, Austin, TX,November 1972.

43. Supplementary Report on Particulate Emissions from Bethlehem Mines Corporations MillardQuarry Hydrate Plant Scrubber, Bethlehem Steel Corporation, Bethlehem, PA, August 1975.

44. Preliminary Test Survey: Gold Bond Building Products, Gibsonburg, Ohio, Monsanto ResearchCorporation, Dayton, OH, April 1975.

45. Preliminary Test Survey: National Lime and Stone Company, Carey, Ohio, Monsanto ResearchCorporation, Dayton, OH, April 1975.

46. Stack Measurements at Austin White Lime, McNeil, Texas, Texas State Department of Health,Austin, TX, October 1971.

47. Report of Determination Stack Emission Investigation, Plant No. 4, Test No. 10 and 11, (Exhibit 4supplied by the National Lime Association), February 1977.

48. Results of Particulate Emission Tests at Basic Magnesia, Inc., Environmental Science andEngineering, Gainesville, FL, June 1973.

49. Emission Test Report, Warner Company, Bellefonte, Pennsylvania, Test No. 1771, Department ofHealth, Commonwealth of Pennsylvania, November 11, 1971.

50. Emissions Survey Conducted at Chemstar Lime Company, Located in Bancroft, Idaho, AmericanEnvironmental Testing Company, Inc., Spanish Fork, Utah, February 26, 1993.

63

5. AP-42 SECTION 11.15

LIME MANUFACTURING

A proposed revision of the existing AP-42 Section 8.15, Lime Manufacturing, is presented in thefollowing pages as it would appear in the document.

A-1

APPENDIX A

ESTIMATE OF CARBON DIOXIDE EMISSION FACTOR FOR LIME KILNS

Carbon dioxide (CO2) is emitted from lime manufacturing kilns by two mechanisms: thereduction of carbonate (CO3

-2) in the limestone feed material to CO2 and the oxidation of carbon in thefuel to CO2. In the production of dolomitic lime (CaO@MgO), CO3

-2 is reduced to CO2 according to thefollowing reaction:

CaCO3@MgCO3 + heat 6 2CO2 + CaO@MgO

Therefore, for each mole of dolomitic lime produced, two moles of CO2 are emitted from the process. The molecular weights of CO2 and CaO@MgO are 44 and 96, respectively. Therefore, for every 96 massunits of dolomitic lime produced, 88 mass units of CO2 are emitted. The emission factor for CO2

emissions from this reaction can be estimated in units of pounds (lb) of CO2 emitted per ton of dolomiticlime produced as:

(88 lb CO2/96 lb lime) x 2,000 lb lime/ton lime = 1,830 lb CO2/ton lime

To produce high-calcium lime, CO3-2 in the feed material is reduced to CO2 by the following

reaction:

CaCO3 + heat 6 CO2 + CaO

Using the same procedure as described above for dolomitic lime, the emission factor for CO2 emissionsfrom high-calcium lime production can be estimated as:

(44 lb CO2/56 lb lime) x 2,000 lb lime/ton lime = 1,570 lb CO2/ton lime

Carbon dioxide also is emitted as a result of combustion in the lime kiln. Theoretical emissionsof CO2 from this mechanism can be estimated from the carbon content of the fuel and the fuelconsumption rate. The carbon content of bituminous coal, which is the fuel used most commonly in limekilns, ranges from 75.5 percent to 90.5 percent.1 The midpoint of this range is 83 percent. To estimatethe coal consumption rate, data from 15 references were used. These data are summarized in Table A-1

A-2

Table A-1. SUMMARY OF LIME KILN COAL CONSUMPTION DATA

Type of kiln

Averageproduction rate,

ton/hrAverage coal

feed rate, ton/hr

Coalconsumption,ton/ton lime Ref.

Rotary 500.0 130 0.26 2

14.0 4.65 0.33 3

24.1 4.38 0.18 4

13.2 4.37 0.33 5

30.4 8.50 0.28 6

25.8 6.70 0.26 7

12.2 3.67 0.30 8

21.4 6.07 0.28 9

24.4 6.05 0.25 10

Calcimatic 15.3 4.08 0.27 11

Rotary with preheater 28.7 5.31 0.19 12

Rotary 11.5 4.00 0.35 13

30.0 5.25 0.18 14

19.1 5.72 0.30 15

103.0 27.6 0.27 16

Minimum 0.18

Maximum 0.35

Average 0.27

Standarddeviation

0.054

A-3

. Based on these data, the average coal consumption rate is 540 lbs/ton of lime produced. The emissionfactor for CO2 emissions from coal combustion can be estimated in units of lbs of CO2 emitted per ton ofdolomitic lime produced as:

540 lb coal/ton lime x 0.83 x 44 lb CO2/12 lb coal = 1,640 lb CO2/ton lime

The overall estimated emission factor for CO2 emissions from lime kilns is the sum of theemission factors for each of the two mechanisms. For dolomitic lime the CO2 emission factor isestimated as:

1,830 + 1,640 = 3,470 lbs/ton

A-4

Table A-2. ESTIMATED CO2 EMISSION FACTORS FOR COAL-FIRED LIME KILNS

Type of lime

Coalconsumptionrate, ton/ton

Carbon contentof coal,percent

Emission factor

Due to stone Due to coal Total

kg/Mg lb/ton kg/Mg lb/ton kg/Mg lb/ton

Dolomitic 0.18 75.5 915 1,830 498 997 1,420 2,830

83 915 1,830 550 1,199 1,470 2,930

90.5 915 1,830 595 1,190 1,510 3,020

0.27 75.5 915 1,830 745 1,490 1,660 3,320

83 915 1,830 820 1,640 1,740 3,470

90.5 915 1,830 895 1,790 1,810 3,620

0.35 75.5 915 1,830 970 1,940 1,890 3,770

83 915 1,830 1,065 2,130 1,980 3,960

90.5 915 1,830 1,160 2,320 2,080 4,150

High-calcium 0.18 75.5 785 1,570 498 997 1,290 2,570

83 785 1,570 550 1,100 1,340 2,670

90.5 785 1,570 595 1,190 1,380 2,760

0.27 75.5 785 1,570 745 1,490 1,530 3,060

83 785 1,570 820 1,640 1,610 3,210

90.5 785 1,570 895 1,790 1,680 3,360

0.35 75.5 785 1,570 970 1,940 1,760 3,510

83 785 1,570 1,065 2,130 1,850 3,700

90.5 785 1,570 1,160 2,320 1,950 3,890

For high-calcium lime, the CO2 emission factor is estimated as:

1,570 + 1,640 = 3,210 lb/ton

Table A-2 present the ranges in CO2 emission factors that can be estimated from the data. Theseemission factors are based on the assumptions that the carbon in the coal is completely oxidized to CO2,and that the carbonate in the limestone feed is completely reduced to CO2. However, it is unlikely thatthese two reactions will be complete. Therefore, these emission factors are likely to be biased high.

REFERENCES

1. J. Howard, Fundamentals of Coal Pyrolysis and Hydropyrolysis, Chemistry of Coal Utilization,Second Supplementary Volume, M. Elliott, (ed.), National Academy of Engineering, John Wiley andSons, New York. 1981.

2. Standards Support and Environmental Impact Statement, Volume 1: Proposed Standards ofPerformance for Lime Manufacturing Plants, EPA-450/2-77-007a, U. S. Environmental ProtectionAgency, Research Triangle Park, NC, April 1977.

A-5

3. W. R. Feairheller, and T. L. Peltier, Air Pollution Emission Test, Virginia Lime Company,Ripplemead, VA, EPA Contract No. 68-02-1404, Task 11 (EPA, Office of Air Quality Planning andStandards), Monsanto Research Corporation, Dayton, OH, May 1975.

4. W. R. Feairheller et al., Source Test of a Lime Plant, Standard Lime Company, Woodville, OH, EPAContract No. 68-02-1404, Task 12, (EPA, Office of Air Quality Planning and Standards), MonsantoResearch Corporation, Dayton, OH, December 1975.

5. J. B. Schoch, Exhaust Gas Emission Study, J. E. Baker Company, Millersville, OH, George D.Clayton and Associates, Southfield, MI, June 1974.

6. R. L. Maurice, and P. F. Allard, Stack Emissions Analysis, U.S. Lime Plant, Nelson, AZ, EngineersTesting Laboratories, Inc., Phoenix, AZ, May 1975.

7. T. L. Peltier, Air Pollution Emission Test, Allied Products Company, Montevallo, AL, EPA ContractNo. 68-02-1404, Task 20, (EPA, Office of Air Quality Planning and Standards), Monsanto ResearchCorporation, Dayton, OH, September 1975.

8. Report on the Particulate Emissions from a Lime Kiln Baghouse (Exhibit 1 supplied by the NationalLime Association), August 1977.



11. T. L. Peltier and H. D. Toy, Particulate and Nitrogen Oxide Emission Measurements from LimeKilns, EPA Contract No. 68-02-1404, Task No. 17 (EPA, National Air Data Branch, ResearchTriangle Park, NC), Monsanto Research Corporation, Dayton, OH, October 1975.

12. Air Pollution Emission Test, Kilns 4, 5, and 6, Martin-Marietta Chemical Corporation, Woodville,OH, EMB Report No. 76-LIM-12, U. S. Environmental Protection Agency, Office of Air QualityPlanning and Standards, Research Triangle Park, NC, August 1976.

13. Particulate Emission Tests Conducted on the Unit #2 Lime Kiln in Alabaster, Alabama, for AlliedProducts Corporation, Guardian Systems, Inc., Leeds, AL, October 1990.

14. T. E. Eggleston, Air Pollution Emission Test, Bethlehem Mines Corporation Annville, PA, EMB TestNo. 74-LIM-1, U. S. Environmental Protection Agency, Office of Air Quality Planning andStandards, Research Triangle Park, NC, August 1974.

15. Air Pollution Emission Test, Marblehead Lime Company, Gary, Indiana, Report No. 74-LIM-7,U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards, ResearchTriangle Park, NC, 1974.

16. Stack Sampling Report of Official Air Pollution Emission Test Conducted on Kiln No. 2 Scrubber atJ.E. Baker Company, Millersville, Ohio, Princeton Chemical Research, Inc., Princeton, NJ, October1975.

TABLE 4-1. SUMMARY OF EMISSION TEST REPORTS USED TO DEVELOP EMISSION FACTORS


J. M. Brenner Lancaster, PA Primary crusher, screens,hammermill, final sizing screens

PM 1974

2

Marblehead Lime Bellefonte, PA Rotary kiln PM 1975

3

J. E. Baker Millersville, OH Rotary kiln PM, CO2 1975

5

Virginia Lime Ripplemead, VA Rotary kiln PM, SO2,NOx, CO,CO2

1975

6

Pfizer, Inc. Gibsonburg, OH Rotary kilnMaterials transferProduct loading

PM 1980

7

Standard Lime Woodville, OH Rotary kiln PM, NOx,CO2

1975

8

Dow Chemical Freeport, TX Rotary kiln PM, NOx,CO2

1974

9

J. E. Baker Millersville, OH Rotary kiln PM, SO2,SO3, CO2

1974

10

J. E. Baker Millersville, OH Rotary kiln PM, SO2,CO2

1975

11

Paul Lime Plant Millersville, OH Rotary kiln PM 1975

12

U.S. Lime Nelson, AZ Rotary kiln PM, SO2,CO2

1975

13

Allied Products Montevallo, AL Rotary kiln PM, SO2,NOx, CO,CO2

1975

14

Martin-Marietta Calera, AL Rotary kiln PM, SO2,NOx, CO,CO2

1975

15

Atmospheric hydrator PM

Plant No. 1 Rotary kiln PM, CO2 1977

16


17


18

U.S. Lime City of Industry, CA Atmospheric hydrator PM, CO2 1974

19

National Lime and Stone Carey, OH Calcimatic kiln PM, NOx,CO2

1974

20

Cooler PM, CO2

Martin-Marietta Woodville, OH Rotary kiln SO2, CO2 1976

21

Rotary kiln with preheater CO2



J. E. Baker Millersville, OH Rotary kiln SO2, CO,CO2

1975

22

Allied Products Alabaster, AL Rotary kiln PM, CO2 1990

23


24

Dravo Lime Saginaw, AL Rotary kiln PM, CO2 1986

25

Dravo Lime Saginaw, AL Rotary kiln PM, SO2,NOx,CO2

1991

26

Paul Lime Co. Douglas, AZ Rotary kiln PM 1972

27

Bethlehem Mines Annville, PA Rotary kiln PM, SO2,NOx,CO, CO2

1974

28

Marblehead Lime Gary, IN Rotary kiln PM, SO2,NOx,CO, CO2

1974

29


30

J. E. Baker Millersville, OH Rotary kiln PM 1975

31

Chemstar Lime Co. Bancroft, ID Six raw material processing sources PM 1993

50

Parallel flow regenerative kiln PM, SO2,NOx, CO

TABLE 4-3. SUMMARY OF TEST DATA FOR LIME MANUFACTURING




Datarating

Ref.No.



170(330)

A 6



190(370)

A 7



PM, filterable 15 34-80(68-160)

60(120)

A 7


Large- diametercyclone

PM, filterable 2 97-110(190-210)

100(200)

C 8



0.049(0.097)

A 7



0.28(0.56)

C 28



0.41 (0.83)

D 17



0.55(1.1)

D 3



0.98 (2.0)

D 16



0.51(1.0)

D 18



0.087 (0.17)

C 15



0.13(0.25)

B 26



4.3(8.5)

A 7



0.46(0.93)

D 31


Venturi scrubber PM, filterable 3 2.4-6.5(4.7-13)

4.1(8.2)

C 11



2.0(4.0)

C 10



1.2(2.4)

B 5



0.55 (1.1)

B 24



0.41 (0.82)

B 23



3 0.57-1.5(1.1-2.9)

0.90(1.8)

C 6




2 0.30-0.57(0.61-1.1)

0.43(0.87)

C 8



2 0.077-0.080(0.16-0.16)

0.079(0.16)

C 15



3 0.032-.039(0.064-0.079)

0.035(0.070)

C 28





Datarating

Ref.No.



6 0.13-0.38(0.25-0.75)

0.22 (0.45)

D 16



3 0.026-0.10(0.052-0.21)

0.058(0.12)

D 18



6 0.067-1.4(0.13-2.8)

0.45 (0.90)

D 17



2 0.14-0.18(0.29-0.36)

0.16(0.33)

D 3



3 0.027-0.20(0.054-0.40)

0.12(0.24)

B 5



3 0.20-0.47(0.39-0.93)

0.33 (0.65)

C 10



3 0.030-0.090(0.059-0.18)

0.055 (0.11)

C 11



3 0.20-0.27(0.41-0.54)

0.24(0.48)

D 31


None PM,condensibleorganic

3 0.32-0.81(0.63-1.6)

0.51(1.0)

C 6


None PM, filterableandcondensibleinorganic

3 100-160(200-330)

120(250)

C 5


None SO2 5 1.1-3.1(2.2-6.2)

2.3 (4.6)

B 15


None SO2 3 2.7-3.8(4.3-7.7)

3.1(6.2)

A 6


Fabric filter SO2 3 0.11-0.26(0.22-0.51)

0.18(0.37)

C 28


Fabric filter SO2 5 1.1-3.1(2.2-6.2)

2.3 (4.6)

B 15


Fabric filter SO2 1f 5.3(11)

5.3(11)

D 15


Fabric filter SO2 3 0.0044-0.0066(0.0087-0.011)

0.0066 (0.013)

B 26


Venturi scrubber SO2 3 0.25-0.65(0.50-1.3)

0.40(0.79)

C 10


Venturi scrubber SO2 3 15-19(30-38)

17(34)

D 11


Settling chamber SO2 6 2.1-9.2(4.2-18)

5.8(12)

C 22



SO2 5 0.049-0.20(0.10-0.40)

0.076(0.15)

B 22





Datarating

Ref.No.



SO2 6 0.17-0.30(0.33-0.64)

0.23(0.45)

B 22


Settling chamber SO2 6 5.2-6.6(10-13)

5.9 (12)

C 22


None NOx 3 0.20-1.0(0.40-2.0)

0.56(1.1)

A 8


None NOx 12 0.73-2.3(1.5-4.5)

1.6(3.2)

A 6



1.8(3.6)

C 28



2.7(5.3)

B 15



1.1 (2.1)

B 26


None CO 2 25-27(50-54)

26(52)

D 6


Fabric filter CO 4 0.11-0.83(0.22-1.7)

0.38 (0.76)

B 15


Fabric filter CO 3 0.046-0.088(0.093-0.18)

0.061(0.12)

D 28



CO 8 0.53-4.0(1.1-8.1)

1.4(2.7)

C 22


Settling chamber CO 4 0.25-0.55(0.49-1.1)

0.45(0.90)

C 22


None CO2 2 2,200-2,200(4,500-4,500)

2,200 (4,500)

C 8


None CO2 1 2,100-2,800(4,300-5,500)

2,500(4,900)

C 5


None CO2 5 710-1,500(1,400-3,000)

1,300(2,500)

A 6


Fabric filter CO2 3 1,200-1,300(2,400-2,700)

1,300(2,500)

C 28


Fabric filter CO2 3 not available 1,500(3,100)

C 18


Fabric filter CO2 3 not available 970 (1,900)

D 17


Fabric filter CO2 2 1,100-1,100(2,100-2,200)

1,100 (2,200)

C 15


Fabric filter CO2 6 1,500-1,600(3,100-3,300)

1,600 (3,200)

D 16


Fabric filter CO2 3 1,400-1,500(2,700-3,100)

1,500(3,000)

B 26



1,700(3,400)

B 24



1,500 (3,000)

B 23


Venturi scrubber CO2 1 2,500(4,900)

2,500(4,900)

B 5





Datarating

Ref.No.



2,500 (5,000)

C 10



1,400(2,700)

B 22


Settling chamber CO2 10 360-1,300(730-2,500)

940(1,900)

B 21



CO2 4 1,900-2,300(3,900-4,600)

2,100(4,200)

B 22


Settling chamber CO2 5 1,700(3,300-3,400)

1,700(3,400)

B 22


Venturi scrubber SO3 3 0.10-0.12 (0.20-0.24)

0.11(0.21)

C 10



0.086(0.17)

C 9



0.44 (0.87)

C 12



0.57(1.1)

D 27


ESP PM,condensibleinorganic

2 0.085-0.13(0.17-0.27)

0.11(0.22)

C 9



3 0.0036-0.051(0.0072-0.10)

0.022 (0.045)

D 12



2 0.45-0.46(0.90-0.92)

0.46(0.91)

D 27


ESP NOx 3 1.4-2.1(2.8-4.2)

1.7(3.5)

C 9


ESP CO 3 0.29-2.6(0.59-5.1)

1.1(2.2)

C 9



40(80)

D 30



PM, filterable 3 0.35-0.48(0.69-0.97)

0.44(0.87)

B 14



0.33(0.65)

D 30




3 0.032-0.051(0.064-0.10)

0.041(0.082)

B 14


None SO2 1g 1.4-2.7(2.0-5.5)

1.9(3.9)

D 14



NOx 3 1.2-1.6(2.3-3.2)

1.4(2.7)

B 14





Datarating

Ref.No.



CO 3 0.14-0.82(0.28-1.6)

0.41 (0.83)

B 14



CO2 3 1,600-1,600(3,200-3,300)

1,600 (3,200)

B 14


Venturi scrubber CO2 1 690(1,400)

690(1,400)

D 30



0.83 (1.7)

B 25



1,500 (3,000)

B 25


Multiclone PM, filterable 2 19-65(38-130)

42(84)

C 8



0.59(1.2)

C 13



PM, filterable 6 0.30-0.72(0.61-1.4)

0.56 (1.1)

C 29


Multiclone PM,condensibleinorganic

2 0.039-0.042(0.078-0.083)

0.040(0.081)

C 8




6 0.40-0.68(0.79-1.4)

0.57(1.1)

C 29



PM,condensibleorganic

6 0.0099-0.14(0.020-0.27)

0.076(0.15)

C 29


Gravel bed filter SO2 2 0.026-0.63(0.052-1.3)

0.33 (0.65)

C 13



SO2 6 1.2-2.8(2.4-5.6)

1.9(3.9)

C 21



SO2 6 3.0-3.9(6.0-7.8)

3.2(6.4)

C 29


None NOx 3 2.2-2.3(4.4-4.6)

2.3(4.5)

A 8



NOx 12 0.83-2.3(1.7-4.5)

1.1(2.2)

C 29



CO 3 0.24-8.7(0.48-17)

3.2(6.3)

D 29





Datarating

Ref.No.


None CO2 2 1,400-1,400(2,800-2,800)

1,400(2,800)

C 8


Gravel bed filter CO2 2 2,500-2,600(4,900-5,300)

2,500(5,100)

C 13



1,600(3,200)

B 21


Settling chamber CO2 7 600-1,100(1,200-2,300)

840 (1,700)

B 21



CO2 3 1,100-1,200(2,200-2,400)

1,100 (2,300)

B 21



CO2 6 1,600-1,900(3,200-3,800)

1,700(3,400)

C 29



88(180)

D 20


None PM, filterable 2 6.8-7.0(14-14)

7 (14)

D 20



2 0.036-0.10(0.072-0.19)

0.066(0.13)

D 20



2 0.18-0.23(0.37-0.46)

0.21(0.41)

C 20


None NOx 5 0.039-0.095(0.079-0.19)

0.076 (0.15)

A 20


None CO2 2 2,000(4,000-4,100)

2,000(4,000)

C 20


None CO2 2 670-690(1,300-1,400)

680(1,400)

C 20


Fabric filter PM, filterable 3 0.022-0.028 (0.044-0.056)

0.026(0.051)

A 50


Fabric filter SO2 3 0.00040-0.00080(0.00079-0.0016)

0.00060(0.0012)

A 50



0.12(0.024)

A 50


Fabric filter CO 3 0.21-0.24(0.41-0.48)

0.23(0.45)

A 50

Atmospherichydrator


0.033(0.067)

B 19

Atmospherichydrator


0.087 (0.17)

C 15





Datarating

Ref.No.

Atmospherichydrator


2 0.0046-0.0091(0.0091-0.018)

0.0067(0.013)

B 19

Atmospherichydrator


3 0.010-0.079(0.0071-0.021)

0.0069 (0.014)

C 15

Cooler None PM, filterable 2 2.4-4.5(4.7-9.0)

3.4(6.8)

C 20

Cooler None PM,condensibleinorganic

2 0.0049-0.018(0.010-0.036)

0.011(0.023)

C 20

Cooler None CO2 2 3.8-4.0(7.6-8.0)

3.9(7.8)

C 20

Final sizingscreens

Fabric filter PM, filterable 1 0.0012(0.0023)

0.0012(0.0023)

unrated 2

Primary crusher None PM, filterable 2 0.0076-0.0090(0.015-0.0018)

0.0083(0.017)

C 2

Primary crusher,screen, andhammermill


0.00044(0.00089)

C 2

Scalping screenand hammermill


0.31(0.62)

D 2

Primary crushingh Fabric filter PM, filterable 3 0.00019-0.00023(0.00039-0.00046)

0.00021(0.00043)

A 50

Primaryscreeningi


0.00030(0.00061)

A 50

Crushed materialconveyor transferj

Fabric filter PM, filterable 6 (2.8x10-5-8.1x10-5)(5.6x10-5-0.00016)

4.4x10-5

(8.8x10-5)A 50

Secondary andtertiary screeningk

Fabric filter PM, filterable 3 4.8x10-5-4.0x10-5

(9.5x10-5-0.00016)6.5x10-5

(0.00013)A 50

Material transferand drop points


1.1(2.2)

C 7

Fugitive, productloading (enclosedtruck)


0.31(0.61)

A 7

Fugitive, productloading (opentruck)


0.75(1.50)

B 7

aFilterable PM is that PM collected on or prior to the filter for an EPA Method 5 (or equivalent) sampling train. Condensible PMis that PM collected in the impinger portion of a PM sampling train and analyzed by EPA Method 202. Emission factors forcondensible PM include both organic and inorganic condensible PM. Total PM is that PM collected in the entire sampling trainand analyzed by Methods 5 and 202.

bEmission factors for kilns, coolers, preheaters, and hydrators in units of mass of pollutant emitted per mass of lime produced;emission factors for crushing, screening, grinding, and loading in units of mass of pollutant emitted per mass of stone/lime feed.

cTests conducted on the this kiln are also documented in other references as indicated.dTests conducted on the this kiln are also documented in other references as indicated.eTests conducted on the this kiln are also documented in other references as indicated.fMultiple CEM readings.gA total of 30 CEM readings over a 4-hour period.hIncludes scalping screen, scalping screen discharges, primary crusher, primary crusher discharges, and ore discharge.iIncludes primary screening, including the screen feed, screen discharge, and surge bin discharge.jBased on average of three runs each of emissions from two conveyor transfer points on the conveyor from the primary crusher tothe primary stockpile.


kBased on sum of emissions from two emission points that include conveyor transfer point for the primary stockpile underflow tothe secondary screen, secondary screen, tertiary screen, and tertiary screen discharge.

TABLE 4-5. SUMMARY OF AVERAGE EMISSION FACTORS FOR LIMEMANUFACTURINGa


No. oftests

Emission factor,


Rotary kiln (coal-fired) None Filterable PM 2 180 350 D 6, 7

Rotary kiln (coal-fired) None Filterable PM-10 b 22 42 D 1, 6, 7

Rotary kiln (coal-fired) Large diam.cyclone

Filterable PM 1 60 120 D 7

Rotary kiln (coal-fired) Fabric filter Filterable PM 4 0.14 0.28 D 7, 15, 26, 28

Rotary kiln (coal-fired) Fabric filter Filterable PM-10 b 0.077 0.15 D 1, 7, 15, 26,28

Rotary kiln (coal-fired) ESP Filterable PM 1 4.3 8.5 D 7

Rotary kiln (coal-fired) ESP Filterable PM-10 b 2.2 4.3 D 1, 7


Filterable PM 3 0.72 1.4 D 5, 23, 24

Rotary kiln (coal-fired) None Condensibleinorganic PM

2 0.67 1.3 E 6,8

Rotary kiln (coal-fired) Fabric filter Condensibleinorganic PM

6 0.19 0.38 E 3, 15, 16, 17,18, 28



3 0.14 0.28 D 5, 10, 11

Rotary kiln (coal-fired) None Condensibleorganic PM

1 0.51 1.0 E 6

Rotary kiln (coal-fired) None SO2 2 2.7 5.4 D 6, 15

Rotary kiln (coal-fired) Fabric filter SO2 3 0.83 0.17 D 15, 26, 28

Rotary kiln (coal-fired) Wet scrubber SO2 2 0.15 0.3 D 22

Rotary kiln (coal-fired) None NOx 5 1.6 3.1 C 6, 8, 15, 26,28

Rotary kiln (coal-fired) None CO 3 0.74 1.5 D 15, 22

Rotary kiln (coal-fired) None CO2 9 1,600 3,200 C 5, 6, 21, 22,23, 24, 26


SO3 1 0.11 0.21 E 10

Rotary kiln (gas-fired) ESP Filterable PM 1 0.086 0.17 E 9

Rotary kiln (gas-fired) Gravel bed Filterable PM 2 0.51 0.99 E 12, 27

Rotary kiln (gas-fired) ESP Condensibleinorganic PM

1 0.11 0.22 E 9

Rotary kiln (gas-fired) Gravel bedfilter


1 0.24 0.48 E 12, 27

Rotary kiln (gas-fired) None NOx 1 1.7 3.5 E 9

Rotary kiln (gas-fired) None CO 1 1.1 2.2 E 9





No. oftests

Emission factor,



Venturiscrubber



Venturiscrubber


1 0.041 0.082 D 14


Venturiscrubber

NOx 1 1.4 2.7 D 14


Venturiscrubber

CO 1 0.41 0.83 D 14


Venturiscrubber

CO2 1 1,600 3,200 D 14


Venturiscrubber



Venturiscrubber

CO2 1 1,500 3,000 D 25


Multiclone Filterable PM 1 42 84 E 8


Gravel bedfilter

Filterable PM 1 0.59 1.2 E 13



PM, filterable 1 0.56 1.1 E 29



PM, condensibleinorganic

1 0.57 1.1 E 29



PM, condensibleorganic

1 0.076 0.15 E 29


Multiclone Condensibleinorganic PM

1 0.040 0.081 E 8


Dry PMcontrols

SO2 2 1.1 2.3 E 13, 21



SO2 1 3.2 6.4 E 29


None CO 1 3.2 6.3 E 29


None CO2 3 1,200 2,400 D 21




None Condensibleinorganic PM

1 0.14 0.27 E 20



No. oftests

Emission factor,



None NOx 1 0.076 0.15 D 20


None CO2 1 1,300 2,700 E 20


Fabric filter PM, filterable 1 0.026 0.051 D 50


Fabric filter SO2 1 0.00060 0.0012 D 50


None NOx 1 0.12 0.24 D 50


None CO 1 0.23 0.45 D 50

Atmospheric hydrator Wet scrubber Filterable PM 1 0.033 0.067 D 19

Atmospheric hydrator Wet scrubber Condensibleinorganic PM

1 0.0067 0.013 D 19

Cooler None Filterable PM 1 3.4 6.8 E 20

Cooler None Condensibleinorganic PM

1 0.011 0.023 E 20

Cooler None CO2 1 3.9 7.8 E 20

Primary crushingc None Filterable PM 1 0.0083 0.017 E 2

Scalping screen andhammermillc


Primary crushingd Fabric filter PM, filterable 1 0.00021 0.00043 D 50

Primary screeninge Fabric filter PM, filterable 1 0.00030 0.00061 D 50

Crushed materialconveyor transferf

Fabric filter PM, filterable 1 4.4x10-5 8.8x10-5 D 50

Secondary and tertiaryscreeningg

Fabric filter PM, filterable 1 6.5x10-5 0.00013 D 50

Product transfer andconveyingc


Product loading(enclosed truck)c


Product loading (opentruck)c



aEmission factors in units of kg/Mg (lb/ton) of lime produced except where indicated.bBased on average particle size distribution presented in Table 4-4.cEmission factors in units of kg/Mg (lb/ton) of stone or product processed.dEmission factors in units of kg/Mg (lb/ton) of material processed. Includes scalping screen, scalping screendischarges, primary crusher, primary crusher discharges, and ore discharge.

eEmission factors in units of kg/Mg (lb/ton) of material processed. Includes primary screening, including the screenfeed, screen discharge, and surge bin discharge.

fEmission factors in units of kg/Mg (lb/ton) of material processed. Based on average of three runs each ofemissions from two conveyor transfer points on the conveyor from the primary crusher to the primary stockpile.

gEmission factors in units of kg/Mg (lb/ton) of material processed. Based on sum of emissions from two emissionpoints that include conveyor transfer point for the primary stockpile underflow to the secondary screen, secondaryscreen, tertiary screen, and tertiary screen discharge.

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